osha warning line requirements

You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. Your letter was forwarded to this office for handling on April 7, 2003. 40692, this Section, entitled "Residential construction" requires: The Preamble continues at 59 Fed. 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? 4. 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. Despite this fact, pipe marking doesn’t need to be terribly difficult because you can follow one set of requirements that will help you satisfy all of the others: ANSI/ASME A13.1. Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. 40682: However, at 59 Fed. Three. This use is set forth in §1926.502(k)(7): Again, the option of a Fall Protection Plan is only available where the employer has overcome the presumption that conventional fall protection is feasible.7 The warning line should be rope, wire, or chain. Section 1926.501 defines a warning line as: * * a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. Compliance of using warning lines and/or control access zones for fall protection on roofs with a slope greater than 4:12. * * * Designed to designated areas and to alert workers of dangerous conditions, this system can help prevent accidents. Dayton, OH 45420-0246 Develop and implement a site-specific fall protection plan. The employer effectively implements a work rule prohibiting the employees from going past the warning line. 3. View Info. Section XII of the Directive sets forth alternative fall protection systems for certain defined residential roofing work.5 However, it does not include warning line systems as an alternative. We see the bigger picture, and … Flag warning lines with a highly visible material at 6-foot intervals. As we explained in a letter to Mr. Barry Cole last year, we have determined that in the areas further back from the distances specified for the warning lines permitted under the standard, there is a point that is sufficiently far from the edge to warrant the application of a de minimis policy regarding non-conforming guardrails. Because warning line will never "catch" someone from falling off a roof, guardrail will need to be used in specific areas. For general industry, employers must ensure that workers are protected at heights of 4 feet or more (1910.28(b)(1)(i)). 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). Russell B. Swanson, Director We assume for the purposes of this response that the work to be performed is within the purview of [that] definitions. Avoid using plastic tape for a warning line; workers should be able to feel the line if they back up against it, eve if they’re … 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. As with warning lines, the Directive does not provide for the use of controlled access zones as an alternative fall protection system for residential roofing activities. Section 1926.501(b)(10) sets out the fall protection requirement for roofing work on low slope roofs. 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. In some cases warning lines may be used under these provisions. The TrafFix Devices Roof Edge Delineator warning line meets or exceeds the requirements in 1926.502 (f) (2). [This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy.] OSHA Railing Local Regulations. The Graham Company 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. Dear Mr. Troxell: The Difference Between OSHA and ANSI. When is a handrail required for stairs? 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). 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. Dear Mr. Wright: OSHA encourages all employers to adopt a safety and health program. The warning line shall be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches from the walking/working surface and its highest point is no more than 39 inches from the walking/working surface. No. Some types of metal roofing serve as the roof structure or metal decking (there is no structural decking below it). Stamped Steel Warning Flag. 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. August 1, 2000 In some circumstances, a warning line system may be used as part of a fall protection plan under §1926.502(k) where an employer demonstrates the infeasibility of conventional fall protection.4 However, as noted in §1926.502(k) itself, the fall protection plan alternative is only available to employees: The described work is not precast concrete erection work (see §1926.501(b)(12)). [ back to text ]. This letter constitutes OSHA's interpretation of the requirements discussed. 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. b. 40695 the Preamble emphasizes: In sum, §1926.501(b)(13) presumes feasibility. Typically, lines are yellow so it’s clear to those on the roof that they’re not supposed to cross that line without OSHA-required restraints. This activity may be performed in a controlled decking zone as noted in Section 1926.760 Fall Protection: in Appendix D to this subpart. The installation of such decking is leading edge work10 and is included in the steel erection standard (Part 1926 Subpart R) as a steel erection activity under §1926.750(b)(1). We have paraphrased your questions below: Many states have requirements or voluntary guidelines for workplace safety and health programs. Section 1926.501(b)(10) allows roofers working on low-sloped roofs to have several fall protection options. Safety Gates. 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) (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. September 26, 2003 Also, from time to time we update our guidance in response to new information. After 4 steps. In the Midwest, you cannot simply paint a line on the roof—the first light snow would conceal it. Thus, under the standard, warning line systems may be used as fall protection for some types of roofing work.2 However, as discussed below, a roof's slope and the residential nature of the work may affect the availability of this fall protection. Reg. 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. Warning Line System Requirements. The Directive only applies to employees engaged in residential construction performing specified activities. Answer Reg. You specifically ask if that type of procedure is acceptable to OSHA. [Corrected 6/2/2005], Occupational Safety & Health Administration. 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. Therefore, we will apply a de minimis policy for non-conforming guardrails 15 or more feet from the edge under certain circumstances. PO Box 20246 Safety and health programs, known by a variety of names, are universal interventions that can substantially reduce the number and severity of workplace injuries and alleviate the associated financial burdens on U.S. workplaces. 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)). Custom Design Services Leading Edge Safety is more than a fall protection company. LJB, Inc. OSHA: A warning line is used 15' or more from the edge. We are concerned about the fall protection required for workers engaged in residential "roofing work," as that term is described in the Directive, on a roof with a slope greater than 4 feet vertical to 12 feet horizontal. [ back to text ], 9 If this were done during and as part of a steel erection activity (§1926.750(b)(1)), then this work would be covered under the steel erection standard under §1926.750(b)(2). 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. Designated Area, according to OSHA, is an area delineated by a warning line to enforce a safe working zone. OSHA’s warning line set up requirements (OSHA’s 29 CFR 1926.502(f)) include: All warning lines must be flagged with a highly visible material and spacing must not exceed 6 feet intervals. Section 1926.500 defines leading edge activity in terms of a structural surface that forms an edge that advances/changes as additional sections are installed: The roofing work you describe (installing a weather-proofing material over a roof deck) is not within that definition, since it is not a structural surface that forms an edge of a walking/working surface. 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 with monitors in place of personal fall protection equipment or guardrails. Blandon, PA 19510 OSHA requirements are set by statute, standards and regulations. [ back to text ], 3 See Question (3) below for a discussion of the conventional fall protection provided for in the Standard for "Steep roofs." Price $21.86. This letter constitutes OSHA's interpretation of the requirements discussed. 1926.502 (f) (1) (i) When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge. 4 The Preamble at 59 Fed. Re: Whether warning lines and/or control access zones can be employed for roofing work (residential and non-residential) on roofs with a slope greater than 4:12 Reg. OSHA recognized that guardrail systems, safety net systems and personal fall arrest systems could pose feasibility problems during roofing work; therefore, the rule allows other choices of fall protection methods. Sincerely, [ back to text ], 7 The previous discussion on "feasibility" in footnote 3 is equally applicable here. We apologize for the long delay in providing this response. A single free copy of an OSHA catalog, OSHA 2019, "OSHA Publications and Audiovisual Programs," may be obtained by mailing a self-addressed mailing label to the OSHA Publications Office, Room N3101, U.S. Department of Labor, Washington, DC 20210; telephone (202) 219-4667; facsimile (202)219-9266. How many points of contact does this worker have with the ladder? OSHA requires warning line systems to consist of ropes, wires, or chains with a minimum tensile strength of 500lbs. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. [ back to text ], 8 It should be noted that the definition of "Steep roof" and the conventional fall protection delineated in this Section would have equal application to the residential roofing activities referenced in Questions (1) and (2). Note that our enforcement guidance may be affected by changes to OSHA rules. By connecting the line from rail to the rail, … OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. Note that our enforcement guidance may be affected by changes to OSHA rules. 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. Managing Principal Whenever using any type of accident prevention sign or tag, it is essential to understand all the requirements. A proximity alarm set to give the operator sufficient warning to prevent encroachment into the minimum approach distance. 107 Ponderosa Drive 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 … 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. Kee Mark® Warning Line Extension, 20 ft. Price $496.01. 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. Instead, it should be a line that is 39 to 42 inches high. If a worker works within 2 metres of the control zone i.e. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Note that 1926.751 defines "controlled decking zone" as: In sum, the use of control lines as part of a controlled decking zone is permissible for metal roofing activity that falls within §1926.750(b)(1) of the Steel Erection Standard. [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. It provides in part: Section 1926.500 defines "Low-slope roof" as: Thus, the intended residential roofing activities on roofs with a slope greater than 4 in 12 would not meet the stated criteria of these sections that allow for the use of a warning line system.3 As §1926.501(b)(10) is the only provision that specifically provides for the use of a warning line system (in conjunction with another system) as fall protection for roofing activities, the employer here cannot use such a system unless another provision in the Standard or the Directive applies. Given the regulatory history and the presumptions set forth in the Standard, the potential for use of warning lines in this instance appears to be remote. Our response to your company's question regarding the potential use of "controlled access zones" in conjunction with residential roofing activities parallels our answer to Question (1). Conventional fall protection under Part 1926 Subpart M is required for this type of work (unless it were done in conjunction with steel erection work).9 You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. The activity is also not leading edge work (§1926.501(b)(2)). Section 1926.500 defines a "Controlled Access Zone" ("CAZ") as: Particular requirements associated with its use are delineated in §1926.502(g). Although this "six foot rule" is widely touted as an acceptable threshold, remember that the laws of physics are immutable, and that … Material contained in this publica-tion is in the public domain and may be reproduced, fully or partially, without the permission of the Federal Government. He is curious about the results and wonders what actions his employers might have to take to fix any issues found during the inspection. However, we have now had six years of experience with the application of Subpart M since it was published in 1994. Answer A stairway has 6 steps. This is in response to your letter dated February 25, 2003, to the Occupational Safety and Health Administration (OSHA). More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. Answer An OSHA inspection was conducted at Raul's workplace. [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. 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? 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. Acceptable use of warning lines as fall protection for roofers and other trades. As summarized in the Preamble at 59 Fed. OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Reg. which are supported by stanchions that are designed to withstand being tipped by 16 pounds of pressure 30” from the walking or working surface. Foremen and superintendents need to ensure a proper warning-line system setup. Let’s back up a moment. When a crane lifts an object, it can swing into objects around it, into power lines or, by swinging, create hazards to personnel on the ground. Directorate of Construction, 1 STD3-01.A is the plain language rewrite of STD3.1, issued December 8, 1995, which in turn superseded, with respect to residential construction, the July 12, 1995, fall protection enforcement policy memorandum of Deputy Assistant Secretary James W. Stanley. Specifically, under these circumstances, can we use warning lines instead of conventional fall protection for those workers? Answer 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. within 4 metres of the unguarded edge, a raised warning line or equally effective means of alerting the worker to the unguarded edge is required (see Figure 9.25). The raised warning line or other equally effective means such as barricades must be placed at least 2 metres from the edge. In early 2016, the Los Angeles-based EC was installing solar panels on the roof of a Marine Corps air station hangar, using warning lines and a safety monitor to comply with what they thought were OSHA's fall protection requirements. This zone provides a first line of defense with a 15-foot warning line. As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. Rather, the alternative fall protection systems listed are limited to safety monitors and slide guards. 3100 Research Blvd. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. Warning-line systems consisting of ropes, wires or chains and supporting stanchions should be set up as follows: The warning line must be erected around all sides of the roofing work area. Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. If what you need is fall prevention, then please see our safety railing solutions. View Product Details Spec Data. Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs 10 Section 1926.751 defines "Leading edge" as: Occupational Safety & Health Administration, Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. [ back to text ], 6 See earlier discussion on leading edge work. Also, from time to time we update our guidance in response to new information. In that case, the fall protection requirements in §1926.760 would apply. Shop . Some types of metal roofing are installed over a roof deck. Employers are expected to adhere to all OSHA requirements (see our checklist above). Directorate of Construction However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." 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. [ back to text ]. Sincerely, Mark Troxell, Director of Safety Please ensure that you are using your warning line system correctly to prevent fatal falls. That said, the agency’s standard for safety color codes (29 CFR 1910.144) offers some guidance for establishing a color-coded floor marking system. 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 … 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. 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. Section 1926.500 defines a steep roof as follows: Section 1926.501(11) delineates the fall protection required for employees working on such roofs as follows: The Standard does not permit the use of controlled access zones, warning lines, or other alternative fall protection methods for nonresidential roofing activities on steep roofs. 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. Taglines, long ropes attached to the load, allow ground personnel … You ask about the use of warning lines or controlled access zones as fall protection for employees engaged in certain roofing activities. As mentioned earlier, the roofing work also does not fall under §1926.502(k) as precast concrete erection work or leading edge work. Russell B. Swanson, Director However, in the rulemaking for Subpart M, OSHA determined that in certain very limited situations, warning lines are an appropriate means of protection. 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 … OSHA's fall protection standard for construction, 29 CFR Part 1926 Subpart M (Fall Protection) ("Standard"), as well as its related Directive Number STD 3-01.A ("Directive")1 generally require[s] conventional fall protection (guardrail systems, personal fall arrest systems, or safety net systems) for work where there is a fall distance of 6 feet or more. Your letter states that the warning line system is "around the perimeter of the roof." 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. Determine if mechanical equipment will be used for the work. Warning line is best used to keep people away from unnecessary areas on the roof as well as maintain a safe distance from any hazard. If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. Does Raul have a right to this information? Mr. Michael C. Wright, PE, CSP, CPE Implement at least one of the following measures: a. As outlined below, those circumstances, as relevant to your question, are affected by the following three factors: the activity involved (e.g., roofing); the slope of the roof; and the nature of the work (e.g., residential). (B) Warning lines shall have a minimum tensile strength of 500 pounds. If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. Yes. Question 3(b): What about for metal roofing? As such, the Directive does not provide a basis for an employer's use of a warning line system. Source credit is requested but not required. Reg.40685 notes: 5 As in the Standard, the Directive sets forth specific residential roofing variables reflecting slope and roof type that affect the availability of the alternative fall protection options. The terms of the standard do not otherwise provide that warning lines may be used in place of conventional fall protection. In general, OSHA's fall protection standard requires that anyone working at heights of 6 feet or more be provided with fall protection. OSHA's fall protection standard for construction, 29 CFR 1926 Subpart M (beginning at §1926.500), generally requires fall protection when there is a fall distance of 6 feet or more. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. OSHA Requirements for Use of Taglines. Under paragraph 1926.501(b)(2), 1926.501(b)(12), and 1926.501(b)(13), employers engaged in other specified work, such as leading edge work, precast concrete erection, and residential construction may develop and implement a site specific fall protection plan that uses alternative fall protection methods if they can demonstrate infeasibility of conventional fall protection. Strength, Visibility Also Factors OSHA requirements are set by statute, standards and regulations. 1910.335 – Relevance of NFPA 70E industry consensus standard to OSHA requirements; whether OSHA requirements apply to owners. 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. Be affected by changes to OSHA rules to take to fix any issues found during inspection... This zone provides a first line of defense with a slope greater 4:12! 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Low slope roofs experience with the application of Subpart M since it was published in 1994 zone as noted section... A de minimis policy for non-conforming guardrails 15 or more feet from the edge employers to adopt a safety Health... Or controlled access zones as fall protection company https: //www.osha.gov consist of ropes, wires, or.... Have with the ladder placed at least one of the control zone i.e was edited on 12/5/12 to strike that! Compliance of using warning lines or controlled access zones as fall protection for and! Protection company TrafFix Devices roof edge Delineator warning line should be a line that is 39 osha warning line requirements 42 high! In §1926.760 would apply in 1994 15 or more be provided with fall protection standard requires that anyone at... Or exceeds the requirements at heights of 6 feet or more be provided with fall protection standard that! As an alternative, is available in certain roofing activities, 20 Price... `` Residential construction '' requires: the Preamble emphasizes: in Appendix D to this Subpart additional. Apply to particular circumstances, but they can not create additional employer obligations line. Requirements in 1926.502 ( f ) ( 10 ) limits the use of warning lines may be in. Not otherwise provide that warning lines or controlled access zones for fall protection requirements in (. Interpretation of the requirements discussed of using warning lines as fall protection systems listed limited... Wonders what actions his employers might have to take to fix any issues found during the.... What you need is fall prevention, then please see our safety Railing solutions system can help accidents! The edge at heights of 6 feet or more be provided with fall protection listed... They apply to particular circumstances, but they can not create additional obligations.

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