OSHA moves residential roof transition date to December 15, 2012

The residential roofing industry has seen several changes since June 2011, 

when OSHA rescinded its directive for residential fall protection requirements. Several deadlines have seemingly come and gone adding to the confusion regarding when those working at heights within residential construction needed to be in compliance with OHSA’s new guidelines.

The new requirements within the residential fall protection directive 

STD 03-11-002 remain in effect, meaning employers must move to adopt these new requirement, OSHA has implemented a transition period for temporary enforcement measures for 19 months until December 15, 2012 which include on-site compliance assistance, penalty reduction, extended abatement dates and increased outreach programs in an attempt to educate the residential construction industry of these new requirements.

OSHA Residental Roofing Reminder

The United States Department of Labor’s Occupational Safety and Health Administration (OSHA) recently

rescinded the interim enforcement policy on fall protection for specified residential construction activities. Under the new policy, employers engaged in residential construction must comply with 29 CFR 1926.501(b)(13).

Enforcement of this new residential roofing directive began September 15, 2011.

“Under 29 CFR 1926.501(b)(13), workers engaged in residential construction six (6) feet or more above lower levels must be protected by conventional fall protection (i.e., guardrail systems, safety net systems, or personal fall arrest systems) or alternative fall protection measures allowed under 1926.501(b) for particular types of work.

A personal fall arrest system may consist of a full body harness, a deceleration device, a lanyard, and an anchor point. (See the definition of “personal fall arrest system” in 29 CFR 1926.500). If an employer can demonstrate that fall protection required under 1926.501(b)(13) is infeasible or presents a greater hazard it must implement a written, site-specific fall protection plan meeting the requirements of 29 CFR 1926.502(k). The fall protection plan must specify alternative measures that will be used to eliminate or reduce the possibility of employee falls.”*

For purposes of determining the applicability of section 1926.501(b)(13), the term “residential construction” is interpreted as covering construction work that satisfies the following two elements:

(1) The end-use of the structure being built must be as a home, i.e., a dwelling; and
(2) The structure being built must be constructed using traditional wood frame construction materials and
     methods.

For more information regarding changes to fall protection requirements in the residential construction industry, please visit www.osha.gov/doc/residential_fall_protection.html

Fall Protection Residental Roofing

Fall Protection in Residential Construction

The United States Department of Labor’s Occupational Safety and Health Administration (OSHA) has
issued a directive rescinding the Interim Fall Protection Compliance Guidelines for Residential Construction
(STD 03-00-001).

Before issuance of this new directive, STD 03-00-001 allowed employers engaged in certain residential construction activities to use specified alternative methods of fall protection (e.g., slide guards or safety monitor systems) rather than the conventional fall protection (guardrails, safety nets, or personal fall arrest systems) required by the residential construction fall protection standard (29 CFR1926.501(b)(13)).

With the issuance of the new directive, all residential construction employers must comply with 29CFR 1926.501(b)(13). Residential construction employers generally must ensure that employees working six feet or more above lower levels use guardrails, safety nets, or personal fall arrest systems DIRECTIVE NUMBER: STD 03-11-002

EFFECTIVE DATE: December 16, 2010

ENFORCEMENT DATE: June 16, 2011