Understanding Aspects of the 29 CFR 1926 Fall Protection Construction Standard

In brief, we have determined that some entities interpret the OSHA fall protection standard for construction differently than perhaps OSHA intends. As such, we will address one specific item in particular. Normally, when on an elevated work platform such as a roof, there must be compliant fall protection in place. This may include barriers or personal fall protection PPE, among other means of protection. However sometimes the relief granted in 29 CFR 1926.500 may be exploited beyond practical interpretation of the Standard. Take for example an inspector visiting a roof top to take measurements or perhaps only to photograph the roof.  If their visit to the roof can be reasonably coupled with construction activity (pending, current or recently completed), they are granted relief in that they need not wear fall protection PPE. Per position and interpretation letters from OSHA, this relief turns on the expectation from OSHA that the person or persons on the roof (or other elevated work platform) are not conducting tasks that require focused trade type work. But use caution when applying this relief.  While OSHA seems to not have attached a definitive time window on applying this relief, if there is no reasonable timeframe of attachment to pending, current or completed construction, by default, this relief is null. In other words, don’t send personnel onto a roof to for example take photos for an insurance property survey years after construction and expect that their activities are covered under 1926; in our view, they are not.

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