The 90-day phase-in period giving residential construction companies additional time to come into compliance with OSHA’s new “Compliance Guidance for Residential Construction” directive (STD 03-11-002) on fall protection ends on Sept. 15. Builders must take whatever steps are needed to be in compliance with OSHA’s Subpart M-Fall Protection beginning on Sept. 16.
Employers are being required to provide conventional fall protection systems — guardrails, personal fall arrest systems or safety nets — when workers are exposed to falls six feet or more above a lower level. There is an exception if an employer determines that using conventional fall protection is either infeasible or creates a greater hazard. In that case, the employer can implement alternative fall protection practices and must provide a written fall protection plan. OSHA is presuming that conventional fall protection systems can be used for most tasks, putting the burden on the employer to demonstrate otherwise.
Many states operate their own state occupational safety and health plans and may have adopted fall protection standards that are different from OSHA’s. Builders who work in states with an approved occupational safety and health plan should contact their local administrator or home builders association for further information on the standards that apply. Going forward, NAHB is continuing to work with OSHA to resolve compliance questions and the content of ongoing training efforts.
For more information on fall protection requirements and the phase-in, visit www.nahb.org/fallprotection; see OSHA’s residential fall protection compliance assistance website; or contactRob Matuga at 800-368-5242, x8507.