May 30, 2011
Nation's Building News

The Official Online Weekly Newspaper of NAHB

OSHA Refuses to Extend Deadline for Fall Protection Guidelines

The Occupational Safety and Health Administration is holding fast to its June 16 deadline for home builders and remodelers to begin providing conventional fall protection systems — such as personal fall arrest systems, safety nets or guardrails — when any employees are working six feet or more off the ground.

The agency’s decision followed a May 26 meeting with OSHA officials at which NAHB leaders reiterated their concern that more training is needed so that builders and trade contractors understand what they are required to do in order to comply with OSHA's fall protection regulation.

Last December, OSHA rescinded its Interim Fall Protection Compliance Guidelines for Residential Construction (STD 03-00-001 – STD 3-0.1A), which had been in place since 1995.

While fall protection has always been required in residential construction, OSHA’s Interim Fall Protection Compliance Guidelines allowed builders the option of using alternative fall protection procedures without first showing they were infeasible or presented a greater hazard to workers, and without a written fall protection plan.

As of mid-June, employers will be required to provide conventional fall protection systems when any worker is exposed to a fall hazard when working six feet or more above the next lower level.

However, the new Compliance Guidance for Residential Construction will also require employers to follow OSHA’s Subpart M Fall Protection Regulation, which does allow the flexibility of using a written fall protection plan and alternative fall protection procedures when conventional systems are either infeasible or using them creates a greater hazard.

On May 26, NAHB First Vice Chair Barry Rutenberg, Construction Safety and Health Committee Chair Dean Mon and NAHB staff met with Assistant Secretary of Labor for OSHA David Michaels and other high-level OSHA officials to discuss their concerns and request an extension.

The agency refused, citing the fact that 15 states had never adopted the interim guidelines and that OSHA has included sufficient flexibility to allow for the use of alternative fall protection measures in the Subpart M Fall Protection Regulation.

OSHA leaders did promise to write a letter to NAHB members confirming that if employers are following NAHB’s fall protection training and educational materials, they will not be cited under OSHA’s fall protection regulation.

Michaels also encouraged NAHB members to use OSHA’s On-site Consultation program, which enables employers to investigate potential hazards at their work sites and even qualify for a one-year exemption from routine OSHA inspections. These on-site consultation services are separate from enforcement and do not result in penalties or citations.

Among the significant changes resulting from the withdrawal of OSHA’s Interim Fall Protection Compliance Guidelines:

  • Roofing contractors must use guardrails, personal fall arrest systems (harnesses and lanyards) or safety nets on all roofs with slopes exceeding 4-in-12 when working six feet or more above a lower level.

  • All other trade contractors must use guardrails or personal fall arrest systems (harnesses and lanyards) or safety nets when the height from one elevation to another is greater than six feet. However, employers who can demonstrate that these fall protection systems are not feasible or create a greater hazard can create a plan outlining alternative fall protection measures, and they must be followed.

  • The fall protection plan must be in writing and site-specific. However, a written plan developed for repeated use for a particular model or style of home will be considered site-specific.

  • The use of fall protection plans is limited to “residential construction,” in which the structure will be used as a home and constructed with traditional wood frame materials and methods (although the limited use of structural steel in a predominantly wood-framed home — such as a steel I-beam to help support wood framing — does not disqualify a structure from being considered residential construction).

Many states operate their own state occupational safety and health plans and may have adopted fall protection standards that are different from Federal OSHA.  If you live in a state with an approved occupational safety and health plan, contact your local administrator or home builders association for further information on the standards applicable in your state. 

A list of the OSHA “state plan states” can be found here:

For more information about the residential fall protection requirements, visit; or email Rob Matuga, or call him at 800-368-5242 x8507.

Boost Job Site Safety With Fall Protection Training Products

In an effort to increase job site safety and reduce the chance of job related accidents, NAHB has produced the “Fall Protection Video, English-Spanish” and “NAHB-OSHA Fall Protection Handbook, English-Spanish.”

Both are available through

The 30-minute “Fall Protection Video, English-Spanish” can be used by builders to train workers to use safe work practices that eliminate fall hazards and comply with OSHA fall-protection standards.

The “NAHB-OSHA Fall Protection Handbook, English-Spanish” provides guidelines for creating a written fall-protection plan and identifying safe work practices that can prevent costly accidents and injuries. Written with clear text, photographs and illustrations, the book serves as a user-friendly resource for promoting safety on any job site.

To purchase the handbook and video online, click here, or call 800-223-2665.

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