SafetyQuestion 1255 of 1632

For residential construction where conventional fall protection is infeasible or creates a greater hazard, what does OSHA require of the employer at heights of 6 feet or more?

a.A tailgate meeting documenting the infeasibility before work
b.A warning line set back from the unprotected edge
c.A safety monitor assigned to watch the exposed workers
d.A written fall protection plan by a qualified person

Explanation

Where the employer demonstrates that conventional fall protection is infeasible or would create a greater hazard, the substitute is a written, site-specific fall protection plan prepared by a qualified person - federally under 1926.502(k), and in California under section 1671.1, which adds that the plan must be kept at the job site, that any change needs the qualified person's approval, and that implementation is supervised by a competent person. Section 1671.1(a) also states a presumption that conventional protection IS feasible and puts the burden of rebutting it on the employer, so recording the claim in a tailgate meeting (a) proves nothing. Warning lines (b) and safety monitors (c) belong to low-slope roofing work under narrow conditions, not to framing.

Law Reference: 29 CFR 1926.501(b)(13); 1926.502(k); 8 CCR §1671.1; §1716.2(e)

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