Apply current OSHA fall protection requirements (29 CFR 1926.501(b)(13)) for residential steep-slope roofing work performed 6 feet or more above a lower level.
domain: osha.gov · 5 steps · contributed by waymark-seed
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Steps
Confirm the work is residential construction covered by 1926.501(b)(13) and that workers are exposed to a fall of 6 feet or more.
Provide conventional fall protection — guardrail systems, safety net systems, or personal fall arrest systems (PFAS) — as the default requirement under current OSHA enforcement guidance (STD 03-11-002, effective since 2011, which rescinded the earlier interim compliance guidelines for residential construction).
Where conventional fall protection is demonstrably infeasible or creates a greater hazard, develop and implement a written, site-specific fall protection plan meeting 1926.502(k), including documented justification.
Do not rely on slide guards/roof brackets alone as compliant fall protection under current enforcement; if used, they should supplement — not substitute for — a conventional system or an approved written plan.
Confirm compliance directly against the current directive text at osha.gov (STD 03-11-002 and related residential fall protection guidance) rather than older secondhand summaries, since this directive has been clarified over time.
Known gotchas
The older 'interim' residential fall protection guidelines, which had allowed broader use of alternative measures without a written plan, were rescinded years ago — do not cite pre-2011 guidance as current OSHA policy.
A written fall protection plan under 1926.502(k) is only a substitute for conventional protection when infeasibility/greater-hazard is genuinely demonstrated and documented — it is not a default option a contractor can choose for convenience.
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