Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. (B) Warning lines shall have a minimum tensile strength of 500 pounds. Develop and implement a site-specific fall protection plan. Designated area warning line If your employees perform maintenance and/or repair activities at least six feet but less than fifteen feet from the roof edge, OSHA also allows “designated areas” delineated by a warning line, assuming the work is infrequent and temporary in nature. However, where the employer can demonstrate that conventional fall protection is infeasible and that a warning line is the most protective alternative means of fall protection, it may be used as part of a residential construction Fall Protection Plan. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. You specifically ask if that type of procedure is acceptable to OSHA. Sincerely, Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs When is a handrail required for stairs? Directorate of Construction Also, at that distance, the failure of a barrier to restrain a worker from unintentionally crossing it would not place the worker in immediate risk of falling off the edge. A proximity alarm set to give the operator sufficient warning to prevent encroachment into the minimum approach distance. OSHA’s employee alarm systems standard 29 CFR 1910.165 applies to all employers that use an alarm system to satisfy any OSHA standard that requires employers to provide an early warning for emergency action, or reaction time for employees to safely escape the work place, the immediate work area, or both. Furthermore, when these other trades use a warning line system in accordance with the policy described above, the workers must use conventional fall protection when they are outside the protection of the warning line system. Taglines, long ropes attached to the load, allow ground personnel … Nor does it include nonresidential roofing work as an activity for which a §1926.502(k) fall protection plan may be used as an alternative to conventional fall protection. (C) The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over. This responds to your July 19, 1999 letter to the Occupational Safety and Health Administration (OSHA) requesting clarification on the use of fall protection for employees, other than roofers, working on low slope roofs. Many states have requirements or voluntary guidelines for workplace safety and health programs. To meet OSHA requirements in the construction industry, employers must provide workers with fall protection whenever they work at heights of six feet or more above a lower level (29 CFR 1926.501(b)(1)). How many points of contact does this worker have with the ladder? Mr. Michael C. Wright, PE, CSP, CPE Source credit is requested but not required. Specifically, we will consider the use of certain physical barriers that fail to meet the criteria for a guardrail a de minimis violation of the guardrail criteria in §1926.502(b) where all of the following are met: In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. The terms of the standard do not otherwise provide that warning lines may be used in place of conventional fall protection. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. As mentioned earlier, the roofing work also does not fall under §1926.502(k) as precast concrete erection work or leading edge work. PO Box 20246 Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. at 40677: As the described roofing activities are not related to overhand brick laying, precast concrete work, or leading edge work6, the only potential in the Standard for use of a controlled access zone again arises in the context of a Fall Protection Plan for residential construction work. Reg. Kee Mark® Warning Line Extension, 20 ft. Price $496.01. Although this "six foot rule" is widely touted as an acceptable threshold, remember that the laws of physics are immutable, and that … Section 1926.501 defines a warning line as: Section 1926.502 (fall protections systems criteria and practices) provides: Significantly, the definition and the referenced §1926.501(b)(10) both refer to or relate to roofing work. In such a setting, can a roofing contractor use controlled access zones or warning lines when engaged in roofing activity on a roof with a slope greater than 4 feet vertical to 12 feet horizontal? Blandon, PA 19510 A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and ; The employer effectively implements a work rule prohibiting the employees from going past the warning line. Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination … A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and. Sincerely, In a few, very specific situations (low-slope roof work, some leading edge work, precast concrete erection and residential construction), because of feasibility limitations, the standard permits the use of a warning line, in combination with other measures, instead of conventional fall protection (guardrail systems, personal fall arrest systems or safety net systems) to keep employees away from an edge. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. Erect and maintain an elevated warning line, barricade, or line of signs, in view of operator, at the required minimum approach distance (see detailed requirements in OSHA regulation). [07/25/2003] 1910.335 – Use of general protective equipment and tools by employees when working near exposed energized conductors or circuit parts in the workplace. Your letter states that the warning line system is "around the perimeter of the roof." OSHA: A warning line is used 15' or more from the edge. For general industry, employers must ensure that workers are protected at heights of 4 feet or more (1910.28(b)(1)(i)). The installation of that type of metal roofing is not leading edge work, since it is not structural, and does not form an edge of a walking/working surface. If a worker works within 2 metres of the control zone i.e. Question (3)(a): We are interested in the availability of alternative fall protection for roofing activities (such as tile, shingle, tar and felt) in the nonresidential construction arena (work not covered by STD 3-0.1A). [ back to text ]. Rather, the alternative fall protection systems listed are limited to safety monitors and slide guards. [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to … Stamped Steel Warning Flag. Warning lines are to be supported so the lowest point of the sag is no less than 34 inches and no more than 39 inches from the walking/working surface. Implement at least one of the following measures: a. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. Question (2): Assuming the same scenario set forth in the first paragraph of Question (1), can controlled access zones be used for residential roofing activities when the roof slope is greater than 4 feet vertical to 12 feet horizontal? Question (1): 29 CFR 1926.500-1926.503 and OSHA Directive Number STD 3-01.A set[s] forth OSHA's requirements with regard to fall protection for certain residential construction activities, including roofing. Answer The Graham Company Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. Dear Mr. Wright: As summarized in the Preamble at 59 Fed. Warning lines have specification requirements that include: Warning lines can consist of rope, wire or similar material with a tensile strength of at least 500 pounds. Main OSHA Warning Line System requirements – 1926.502 (f) Flagging on the warning line shall be of a highly visible material and spacing must not exceed 6′ – 1926.502 (f) (2) (i) The lowest point of sag shall not be less than 34″ or greater than 39″ – 1926.502 (f) (2) (ii) Section 1926.501(b)(10) allows roofers working on low-sloped roofs to have several fall protection options. Acceptable use of warning lines as fall protection for roofers and other trades. We apologize for the delay in responding. If what you need is fall prevention, then please see our safety railing solutions. Strength, Visibility Also Factors As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. In your letter you state that other trades (for example, electricians and mechanical trades), when working on roofs, tie-off only when they go outside the warning line system. OSHA offers no requirements for specific floor marking colors; however, a 1972 OSHA interpretation states that lines meant to define aisles may be any color, provided they clearly lay out the aisle. At 15 feet from the edge, a warning line, combined with effective work rules, can be expected to prevent workers from going past the line and approaching the edge. Foremen and superintendents need to ensure a proper warning-line system setup. The Directive only applies to employees engaged in residential construction performing specified activities. Also, from time to time we update our guidance in response to new information. Is available in certain roofing activities are set by statute, standards and regulations on leading edge work ( (... 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