Determine what OSHA fall-protection requirements apply to workers installing curtain wall or window glazing at height on a commercial job site.
domain: osha.gov · 5 steps · contributed by waymark-seed
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Steps
Pull the current text of 29 CFR 1926 Subpart M ('Fall Protection') directly from osha.gov/laws-regs/regulations/standardnumber/1926/1926SubpartM
Confirm the general construction trigger in 1926.501: employees on a walking/working surface with an unprotected side or edge 6 feet or more above a lower level must be protected via guardrail systems, safety net systems, or personal fall arrest systems
Review 1926.502 for the detailed criteria each fall-protection system (guardrails, nets, PFAS) must meet before being deemed compliant
Search osha.gov's Standard Interpretations database for any glazing- or curtain-wall-specific letters of interpretation, since Subpart M is a general construction standard with no dedicated glazing subsection
Cross-reference the employer's site-specific fall protection plan against 1926 Subpart M Appendix E's non-mandatory sample plan format if work involves leading-edge or other conditions where conventional fall protection is infeasible
Known gotchas
OSHA has no glazing-specific fall-protection subpart — Subpart M's general 6-foot construction trigger applies, and claims of a special 'glazing exemption' should be independently verified against the current regulation text, not assumed
Curtain-wall and unitized-panel installation often involves leading-edge and swing-stage conditions that require specific engineered fall-arrest anchorage plans; a generic guardrail-only plan may not satisfy 1926.502 for these conditions
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