NOTICE
The following four groups of Alternative Fall Protection Plans for Residential Construction may be reproduced for the sole purpose of providing educational information about OSHA's Interim Fall Protection Compliance Guidelines for Residential Construction.
Permission granted by Hilton Hilliard & Associates, L.L.C., The Publisher (888) 237-7163
"This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal or other professional advise is required, the services of a competent professional should be sought."
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OSHA INTERIM RESIDENTIAL FALL PROTECTION PLAN
Notice: This explanation is presented from a Builder – Independent Contractor contractual relationship (for the residential builder who subcontracts all construction work to others). OSHA Regulations (including Subpart M – Fall Protection) are directed to an Employer – Employee Relationship.
GROUP I – ALTERNATIVE PROCEDURES
Installation of Floor Joists, Floor Sheathing, and Roof Sheathing; Erecting Exterior Walls; Setting and Bracing Roof Trusses and Rafters
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Location of the RESIDENTIAL BUILDER'S Community or Project
Fall Protection Systems (Conventional or Alternative) are required for all residential construction activity six feet or more above lower levels.
Each Alternative Fall Protection Plan is Designed to be Used in the Field. The construction manager ("Competent Person") must refer to each fall protection plan and determine which part of the alternative procedure plan is to be put in place by the builder and which part of the alternative procedure plan is the responsibility of the Independent Contractor ("Competent Person").
A. General Requirements For Group 1 Activities.
Training, Implementation/ Supervision by Designated Individuals, Controlled Access Zones, Plan Administration (required for all Group 1 activities).
The builder and each independent contractor must have their own "Competent Person" employee in charge of each project and a "Qualified Person" in charge of each plan.
B. Implementation of the Alternative Procedures – Group I
A fall protection plan is required. It does not have to be written to use the alternative procedures in Group I Activities.
However, the plan (written or not) must be implemented using the following procedures and OSHA regulations.
1. Training — Group I
Each employer is responsible for the safety training and education of their own employees. (1926.21)
The "Competent Person" of the employer must identify each entrant (their employee) performing alternative procedures activities as an authorized entrant after the employee has successfully completed the training from his/her employer.
The Independent Contractor must ensure that its employees (and its subcontractors employees):
Note: Any concerns raised by the Independent Contractor’s employees (or its subcontractor’s employees) at any time during construction must be addressed (determined to be valid or not) before work proceeds.
Important Notice: Subsection 1926.503 Training Requirements (b) Certification of Training no longer applies to residential construction. (This provision requires the employer to maintain a written list containing the name of each employee and the date training was completed.)
2. Supervision of the Alternative Procedures – Group I
a. The Builder and the Independent Contractor must each designate a "Competent Person", who will be charged with implementing each plan. The "Competent Person" must continually monitor compliance with each plan, including the provision of training and the proper use of Controlled Access Zones.
"Competent Person" means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
b. The Builder and the Independent Contractor must designate a "Qualified Person" to approve any changes to a plan.
"Qualified Person" means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems relating to the subject matter, the work or the project.
c. Crew Supervisor/Foreman — The Independent Contractor must designate a crew supervisor or foreman and charge him/her with the responsibility of immediately correcting any unsafe practice or condition.
d. Walking/Working Surface means any surface, whether horizontal or vertical on which a worker walks or works, including but not limited to, floors, roofs, ramps, bridges, runways, form work and concrete reinforcing steel, but not including ladders, vehicles, or trailers, on which workers must be located in order to perform their job duties.
3. A Controlled Access Zone will be used six feet or more above lower levels, where Group I activities are taking place.
A Controlled Access Zone. (CAZ) restricts access to a clearly designated area where a Group One activity (installation of floor joists, floor sheathing, roof sheathing; erecting exterior walls; setting and bracing roof trusses and rafters) is taking place. The CAZ must meet the following requirements:
a. Boundaries. The Builder’s competent person and the Independent Contractor’s competent person shall determine the boundaries of the CAZ and clearly mark them with signs, wires, tapes, ropes or chains.
b. Monitor. The Independent Contractor’s crew supervisor/foreman shall monitor their workers in the CAZ to ensure that they do not engage in unsafe practices.
c. Restricted Access. Access to the CAZ must be restricted to authorized entrants. An authorized entrant is a worker of the Independent Contractor who has received the training described above. The Independent Contractor’s competent person must identify each entrant as an authorized entrant after the employee has successfully completed their training.
The builder’s competent person(s) is the only other authorized entrant(s).
d. Final Check. Before work begins in the CAZ, the Independent Contractor’s competent person must ensure that all protective measures in the plan have been implemented.
C. Plan Administration of the Alternative Procedures – Group I
1. Employer Enforcement —. The Builder and the Independent Contractor are required to enforce each plan. The Independent Contractor’s crew supervisor/foreman, as well as individuals in the Safety and Personnel Department, must have the right to issue disciplinary warnings to their own employees, up to and including termination, for failure to follow the requirements of a plan. Unsafe practices or conditions must be corrected immediately.
2. Changes To A Plan.—Designation of qualified person: the Builder and the Independent Contractor must designate a qualified person to approve changes to a plan.
-- Approval required: changes to a plan may not be made unless approved by the qualified person.
- Plan Review: the qualified person must review the plan as the job progresses to determine if additional practices, procedures or training need to be implemented. Each employer shall notify and, if necessary, train their own workers in the new procedures.
D. Additional Requirements for Specific Group 1 Activities
1. Installations of Floor Joists and Floor Sheathing.
a. Installation Process: Floor Joists/Trusses.
The floor joists/trusses are then to be secured from a platform.
The platform is to be built from a sheet of plywood
laid over the previously secured floor joists or trusses.
b. Installation Process: Floor Sheathing.
NOTE: Wall openings (more than six feet above the lower level), floor holes and roof holes:
2. Erection of Exterior Walls.
a. Designated, Trained Workers. The employer (Independent Contractor) must designate the trained workers who will do this work.
b. Warning Line. A painted warning line six (6) feet from the perimeter will be clearly marked before any wall erection activities take place.
NOTE: As discussed above, this work must be done within a CAZ.
c. Staging of Materials. To minimize exposure to fall hazards, materials must be staged so that workers have quick and safe access to them.
d. Limit Fall Hazard Exposure. Workers constructing exterior walls shall complete as much cutting of materials and other preparatory work as possible away from the edge of the deck.
3. Installing Roof Trusses and Erecting Rafters.
a. Walls Up To 8 Feet. Interior scaffolds must be installed along the interior wall, below the area where the trusses/rafters will be located.
This can often be accomplished with "sawhorse" scaffolds constructed of 46 inch sawhorses and 2 x 10 planks.
b. Walls Over 8 Feet. If using scaffolds and ladders throughout the process would create a greater hazard, the following general requirements and specific procedures apply.
(1) Walls over 8 feet. General requirements.
(a) Falling Objects/Restricted Access .Once truss/rafter installation begins,
workers not involved in that activity shall not stand or walk below or adjacent to the roof opening or exterior walls in any area where they could be struck by falling objects.
(b) Bracing. Trusses/rafters must be adequately braced before any worker may use them as a support.
(c) Designated, Trained Workers. The employer (Independent Contractor) must designate the trained workers who will work on the top plate, and those who will work on the peak.
(d) Restricted Duties. Top plate workers shall have no other duties during truss/rafter erection.
(2) Procedures for working on the top plate.
(a) Installing The First Two Trusses.
(b) Remain On The Top Plate. Workers will remain on the top plate and use the previously stabilized trusses/rafters as support while the other trusses/rafters are erected.
(3) Procedures for working at the peak.
(a) When Workers May Work On Peaks/Ridge Beam.
(b) Stable Work Position
4. Roof Sheathing Operations. The competent person (of the Independent Contractor) must determine when the roof system is stable enough to support a conventional fall protection system anchorage.
a. Qualified Workers. Only qualified workers of the Independent Contractor shall install roof sheathing.
b. Secure Footing/Weather.
c. Staging of Materials. To minimize exposure to fall hazards, materials must be staged so that workers on the roof have quick and safe access to them.
d. Falling Objects/Restricted Access.
e. Slide Guards for Roof Sheathing Operations.
(1) Bottom Row:
It must extend across the full width of the roof.
(2) Slide Guard Intervals: Roof Pitch Up To (and including) 9 in12:
Additional slide guards are required at 13 foot intervals as successive rows of sheathing are installed.
(3) Slide Guard Intervals: Roof Pitch Over 9 in 12:
Additional slide guards are required at four foot intervals.
NOTE: These slide guard requirements, which come from Appendix E, differ from those for Group 4 Activities (roofing work).
OSHA INTERIM RESIDENTIAL FALL PROTECTION PLAN
Notice: This explanation is presented from a Builder – Independent Contractor contractual relationship (for the residential builder who subcontracts all construction work to others). OSHA Regulations (including Subpart M – Fall Protection) are directed to an Employer – Employee Relationship.
GROUP 2 – ALTERNATIVE PROCEDURES
WORKING ON CONCRETE AND BLOCK FOUNDATION WALLS AND RELATED FORM WORK.
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1. This specifies the alternative procedures for protecting employees (of the Independent Contractor) working from the top surface of block foundation walls, concrete foundation walls, and related form work. These procedures are:
a. Trained Workers Only.
b. Adequate Support. All form work shall be adequately supported before any worker may work on top of the form work.
c. Bad Weather. When adverse weather (such as high winds, rain, snow, or sleet) creates a hazardous condition, operations shall be suspended until the hazardous condition no longer exists.
d. Staging of Materials/Equipment. Materials and equipment for the work shall be conveniently located to the workers on the top of the foundation/form work.
e. Impalement Hazards.
Ends of all protruding metal, lumber or plastic must be guarded. Mushroom caps are suitable for anchor bolts, rebars, and other objects located on the same surface as the workers.
If workers are on an upper level above the protruding materials mushroom caps are inadequate protection and 2X lumber must be used to cover all protruding objects.
2. Erection of Masonry Walls
Whenever a masonry wall is being constructed, a Limited Access Zone and a Controlled Access Zone shall be established prior to the start of construction.
A Limited Access Zone means an area along the unscaffolded side of the wall, which must be barricaded to limit access.
The builder’s competent person and the Independent Contractor’s competent person must ensure that the Limited Access Zone is clearly marked and controlled by the Independent Contractor
a. The Limited Access Zone (LAZ) must meet the following requirements:
When the height of the wall is over eight (8) feet, it must be adequately braced. The bracing shall remain in place until permanent supporting elements of the structure are in place.
b. The Controlled Access Zone (CAZ)
(1) This means an area in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled (Subpart M, Fall Protection 1926.500 (b) Definitions)
(2) If a worker reaches more than 10 inches below the level of the walking/working surface on which they are working, the worker shall be protected from falling by:
(3) When the CAZ is used to control access to areas where overhead brick laying and related work are taking place:
Only that portion of the guardrail necessary to accomplish that day’s work shall be removed.
OSHA INTERIM RESIDENTIAL FALL PROTECTION PLAN
Notice: This explanation is presented from a Builder – Independent Contractor contractual relationship (for the residential builder who subcontracts all construction work to others). OSHA Regulations (including Subpart M – Fall Protection) are directed to an Employer – Employee Relationship.
GROUP 3 – ALTERNATIVE PROCEDURES
THIS GROUP CONSISTS OF THE FOLLOWING ACTIVITIES WHEN PERFORMED IN ATTICS AND ON ROOFS: INSTALLING DRYWALL, INSULATION, HVAC SYSTEMS, ELECTRICAL SYSTEMS (INCLUDING ALARMS, TELEPHONE LINES, AND CABLE TV), PLUMBING AND CARPENTRY.
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1. Trained Workers Only. Only trained workers (of the various Independent Contractor’s employees and their subcontractor’s employees) shall be allowed to work in attics and on roofs, and only as necessary to complete the construction of the system being installed.
2. Staging of Materials. Materials and equipment for the work shall be located conveniently close to the workers.
3. Impalement Hazards. Materials and other objects which could pose impalement hazards shall be keep out of the area below where workers are working, or properly guarded.
4. Restricted Access.
5. Bad Weather. When adverse weather (such as high winds, rain, snow, or sleet) creates a hazardous condition, operations shall be suspended until the hazardous condition no longer exists.
NOTE: The provisions of this STD 3-0 1A do not apply to interior finishing work when work outside of attics or roofs areas is finished.
Subpart M applies to such work with respect to stairways, stairway openings, walkways, floor or window openings, floor holes or other elevated openings or open sides.
OSHA INTERIM RESIDENTIAL FALL PROTECTION PLAN
Notice: This explanation is presented from a Builder – Independent Contractor contractual relationship (for the residential builder who subcontracts all construction work to others). OSHA Regulations (including Subpart M – Fall Protection) are directed to an Employer – Employee Relationship.
GROUP 4 – ALTERNATIVE PROCEDURES
ROOFING WORK (REMOVAL, REPAIR, OR INSTALLATION OF WEATHERPROOFING ROOFING MATERIALS SUCH AS SHINGLES, TILE AND TARPAPER).
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Restrictions Apply to Group 4, Roofing Work.
(a) the roof slope is 8 in 12 or less,
and
(b) the fall distance, measured from the eave to the ground level, is 25 feet or less.
1. General Requirements.
a. Trained Workers Only.
In addition,
b. Slip Hazards The roof surfaces shall be inspected for slipping hazards.
The employer shall have workers wear appropriate footwear to reduce the potential for slipping.
c. Bad Weather. When adverse weather (such as high winds, rain, snow, or sleet) creates a hazardous condition, roofing operations shall be suspended until the hazardous condition no longer exists.
d. Roof Holes/Openings.
e. Ladders/Scaffolds. If ladders or scaffolds are used,
f. Access To Roof. Employers shall not allow workers to ascend or descend the roof’s slope within 6 feet of the rake edge except where that limitation would prevent the performance of work.
g. Location of Materials. Supplies and materials shall not be stored within 6 feet of the rake edge, or three feet where tile roof systems are being installed.
h. Impalement Hazards.
When workers are on an upper level above protruding materials, mushroom caps are inadequate protection and 2x lumber must be used to cover all protruding objects.
2. For Roofs with an Eave Height Of Up To and Including 25 Feet;
Roofing Slide Guards and
Safety Monitors (of the Independent Contractor)
Will Be Used.
a. Roof Slope (Any Roof Type): Up to 4 in 12.
If roofing slide guards are used, they must be built and installed in accordance with the requirements set out below.
b. Roof Slope: Over 4 in 12 (and up to and including 8 in 12): Roofing Slide Guards are required. (Except Tile or Metal Roofs)
c. Roof Slope: Tile or Metal Roofs - Over 4 in 12 (and up to and including 8 in 12) The safety monitoring system may be used instead of slide guards.
3. Roof slopes over 8 in 12, and over 25 feet
a. Roof Slope (Any Roof Type): Over 8 in 12 - RESTRICTIONS APPLY. Conventional fall protection must be used, either personal fall arrest systems, safety net systems or guardrail systems. Alternative procedures are not available.
b. Eave Height Over 25 feet (Any Slope, Any Roof Type): - RESTRICTIONS APPLY. Conventional fall protection must be used, either personal fall arrest systems, safety net systems, or guardrail systems. Alternative procedures are not available.
4. Roofing Slide Guards: Requirements for Material Configuration and Installation.
a. Employers (Independent Contractors) who use roofing slide guards as fall protection during roofing operations work shall comply with the following requirements:
(1) Materials:
(2) Installation instructions
(a) On steep roofs with slopes greater than 4 in 12,up to and including 6 in 12.
Roofing slide guards shall be installed continuously along the eave.
To accomplish this:
(b) On steep roofs with slopes greater than 6 in 12 up to and including 8 in 12.
(i) Continuous slide guards must be installed across all lower eaves.
(ii) Additional slide guards shall be installed below each work area at intervals not to exceed eight feet.
To install the additional slide guards:
(c) Although the eave slide guards must run the entire length of the eave:
(3) Removal Instructions:
When the roofing job is completed the 2X6 planks and roof jacks along the eave can be removed.
5. Exceptions: (OSHA – Interpretations and Clarifications Subpart M, February 1995)
Once on the roof, the vendor’s employees will receive the roofing products (from a conveyor belt, lift truck or similar equipment) and then distribute the products onto the roof at various locations. During this distribution process, the vendor’s employees are not required to install an anchorage point for fall protection equipment regardless of the slope of the roof or the fall distance.
6. Safety Monitoring System must comply with Subpart M – Fall Protection 1926.502.
a. For residential construction, the Safety Monitoring System is applicable only to certain roofing operations.
(1) Roofing work on low-slope roofs 4 in 12 or less.
On roofs 50 feet or less in width, the use of a safety monitoring system alone (i.e., without the warning line system) is permitted. (or use roofing slide guards)
(2) Tile or Metal Roofs installed on steep roofs up to (and including) 8 in 12.
The Safety Monitoring system may be used instead of slide guards.
b. Safety monitoring systems and their use shall comply with the following provisions.
(1) Safety monitoring system means a safety system in which a competent person (of the Independent Contractor is responsible for recognizing and warning employees of fall hazards.
(2) The Safety Monitor’s duties and responsibilities include:
(3) No employee (or another Independent Contractor’s employee) other than an employee (of the Independent Contractor) engaged in roofing work, shall be allowed in an area where an employee (of the Independent Contractor) is being protected by a safety monitoring system.
(4) Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees (of the Independent contractor) engaged in roofing operations on low sloped roofs.
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END of the Four Alternative Fall Protection Plans