Fall Protection Requirements Your Worksite Needs to Stay OSHA Compliant

OSHA's requirements for fall protection training are some of the most complex and confusing safety standards to navigate.

But as one of OSHA's Focus Four hazards, it's a standard that OSHA inspectors will pay close attention to during a site visit. In this article, we’ll discuss how you can avoid OSHA fines and costly accidents by learning, understanding, and correctly implementing OSHA's requirements for fall protection.

Why Does OSHA Require Fall Protection?

Falls are a leading cause of injury and death across all workplaces, but they're an especially large safety problem for the construction industry.

The industry presents many opportunities for deadly falls because so much of the work is done at height. Fall hazards are more complicated on a construction site because there are other hazards, like heavy machinery, unwieldy materials, and hand or power tools, that compound the danger.

That's why, although falls make up 15% of all workplace fatalities a year, they account for a third of construction fatalities.

It's also why OSHA enforces fall protection standards rigorously. Two of the top 10 most-cited OSHA violations are against fall-related standards.

What Is the Definition of Fall Protection?

OSHA uses the term "fall protection" to refer to any equipment, device, or system that either prevents an employee from falling from an elevation or mitigates the effects of such a fall.

It's worth noting that many safety professionals make a distinction between fall prevention and fall protection, where "fall prevention" is equipment that passively protects workers from an edge while "fall protection" is used to prevent injury in the event of an accidental fall.

 OSHA uses fall protection more broadly to include both.

At What Height Is Fall Protection Required?

While performing construction or demolition work, fall protection is required at 6 feet – but there are a few exceptions.

If you're working on scaffolding, fall protection is required when you're 10 feet above the lower level. If you're involved in steel erection activities, it's 15 feet. If you're on a fixed ladder or rebar assembly, it's 24 feet.

What's the Minimum Height Under Fall Protection Standard §1910?

The answer and its exceptions above apply to the construction industry – it's the fall protection standard under §1926 Subpart M.

The answer is different for the General Industry standard (§1910) and the Shipyard standard (§1915).

In General Industry (which applies to everything except construction and shipyard work), fall protection is required at 4 feet. For shipyards, it's 5 feet.

What Are the Different Types of Fall Protection Systems?

When choosing fall protection, OSHA allows you to use a number of solutions to prevent and mitigate fall hazards.

Each category of fall protection system comes with a long list of specs and requirements for OSHA compliance, but we'll introduce the basics below.

Guardrails, safety net systems, and personal fall arrest systems are considered conventional fall protection and should be used in most cases. Positioning systems, personal restraint systems, controlled access zones, and safety monitoring systems may only be used when performing certain activities.

1. Guardrail Systems

Guardrails are barriers that prevent workers from falling to a lower level. OSHA requires guardrail systems to be capable of withstanding a force of at least 200 pounds at any point within 2 inches of the top edge applied in any outward or downward direction. Guardrail systems also need to have a surface that protects workers from punctures, lacerations, or snagging.

2. Safety Net Systems

Safety net systems are required when working more than 25 feet above the ground, water, or other surfaces when the use of ladders, scaffolds, catch platforms, temporary floors, safety lines, or safety belts is impractical. A common example is bridge work.

Safety nets must be installed as close as is practical beneath the walking/working surface, but never more than 30 feet down. There must be sufficient clearance beneath the net to prevent contact with the surface or structure below, and drop-testing is required after installation to ensure everything is working properly.

3. Personal Fall Arrest Systems

Personal fall arrest systems are designed to safely arrest an accidental fall. Specifically, they arrest a fall before a worker can fall more than 6 feet or impact the lower level in any way.

Personal fall arrest systems include an anchorage, body harness, and connectors, sometimes accompanied by a lanyard, deceleration device, lifeline, or some combination of these components.

4. Positioning Device Systems

While personal fall arrest systems are a mitigation measure, positioning device systems are designed to prevent a fall. It allows the wearer to work with both hands at height while being held in place.

Although positioning systems are not intended to arrest a fall, OSHA requires them to be capable of keeping workers from free-falling more than 2 feet, so while they're required to have twice the capacity of that potential impact, that's not nearly as much force as a six-foot fall. That's why body belts, which are forbidden in a fall arrest system, are acceptable in a positioning device system.

5. Fall Restraint Systems

Fall restraint systems are also a prevention measure. Unlike a positioning system, which allows a small fall, a restraint system prevents the worker from falling any distance whatsoever. As a result, they don't require any of the give that you need in an arrest or positioning system. The anchorage has to be strong enough to prevent the worker from reaching an unprotected edge.

It's worth noting that fall restraint systems aren't specifically mentioned as an acceptable fall protection system in §1926 Subpart M. However, OSHA does recognize them as fall safety equipment, including in their own literature.

6. Warning Line Systems

A warning line system acts as a barrier for roof work – but it's not designed to bear weight like a guardrail system. Instead, it's merely a warning to workers that they're approaching an unprotected edge.

Warning lines can be used to indicate where the roof can take place without the use of guardrails, body harnesses, or safety net systems. The minimum distance from an edge is 6 feet, but it's more if there's mechanical equipment in use.

7. Controlled Access Zones

Controlled access zones are areas where certain kinds of work can take place without conventional fall protection systems. Access to these zones should be carefully controlled. They're marked off by control lines, which must be at least 6 feet from the nearest unprotected edge, just like warning lines.

For example, controlled access zones are used for overhand bricklaying without the protection of guardrails. Only masons and other necessary workers will enter.

8. Safety Monitoring Systems

Safety monitoring systems can be used for low-slope roofing work when there's no mechanical equipment. Unlike other fall protection systems, a safety monitoring system doesn't use physical components like barriers, harnesses, or lanyards.

It's just a competent person whose attention is entirely focused on whether workers are too close to a fall hazard or acting in an unsafe manner. OSHA requires the monitor to be on the same walking or working surface as the workers, within easy sight and sound. They can't be assigned any other duties.

What is OSHA's Skylight Fall Protection Requirement?

OSHA considers a skylight to be a hole in the walking/working surface of the roof, even if the skylight is fully installed. That's because the skylight material may not be capable of handling the force of a falling adult without breaking – especially when it's been weathering for years.

Under §1926.501(b)(4)(i), construction employees must be protected from such holes when there are more than 6 feet above the lower level. You have four options: personal fall arrest systems, covers, or guard rails.

There are a few products that can meet these requirements. You can get mesh skylight screens that cover the skylight without drilling. The mesh takes the fall instead of the skylight material.

There are also skylight guardrails that can be installed permanently or temporarily. Just remember that OSHA requires rooftop guardrails to be at least 42 inches tall.

Finally, you can choose to use a fall arrest or restraint system.

What's a Ladder Fall Protection System?

Under the OSHA fall protection standard (§1910), fixed ladders that top out at 24 feet above the ground or less do not require fall protection systems. Portable ladders don't have a fall protection requirement.

For fixed ladders with a fall hazard of 24 feet or more, you need either a ladder safety system or a personal fall arrest system to be OSHA compliant. Personal fall protection and ladder safety systems need to provide protection throughout the entire vertical distance of the ladder.

You used to be able to meet fall protection requirements on fixed ladders with a cage or well, but this option was phased out in favor of either a personal fall arrest system or a "ladder safety system" in 2018. Cages or wells still meet requirements for ladders built before the change, but if that ladder needs to be replaced, it has to be upgraded to meet the new requirements.

What Are the OSHA Requirements for Fall Protection Training?

According to §1926.503, construction employers must provide each employee who might be exposed to fall hazards with training by a competent person, as well as keep a written certification record for the training.

The training needs to cover the:

• Nature of fall hazards in the work area
• Correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems that will be used
• Use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection that will be used
• Role of each employee in the safety monitoring system when it's used
• Limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs
• Correct procedure for handling and storage of equipment and materials and the erection of overhead protection
• Role of employees in fall protection plans
• Relevant OSHA standards

Unlike other standards that require training, there's no prescribed frequency for refresher training. Retraining is required if there are changes that render previous training obsolete, changes in the type of fall protection systems or equipment to be used, or inadequacies in the affected employee’s knowledge or use of fall protection systems.

Given how prevalent fall hazards and incidents are in construction, employers can (and do) train on the subject regularly to make sure the knowledge and application are fresh in their workers' minds.

Some jurisdictions have even more rigorous training requirements than the federal agency. For example, New York City's Department of Buildings (NYC DOB) requires 8 hours of fall protection training for new entrants into the city's construction work.

Where Do You Get OSHA-Authorized Fall Training Online?

Online training from an OSHA-authorized training provider like us can be a great way for construction companies to provide consistent, compliant, and thorough fall protection training.

The courses are self-paced and available 24/7 so that employees can work through them when and where it's convenient and make sure they really understand the material. And for employers, they're efficient both in terms of cost and time. Plus, the proof of certification for the whole crew is organized and stored electronically whenever you need it.

We've successfully provided online OSHA training for over 20 years. Our OSHA Fall Protection course is a great way to get a solid background on fall hazards and protection measures. Or, if you want a more general safety primer, OSHA 10 and 30 Construction cards include a fall protection component to a much broader base.

If you're in New York City, subject to SST requirements, we have 8-hour SST Fall Protection, 4-hour SST Fall Protection (for refreshers), and a number of SST packages that include the appropriate fall protection course.

Enroll today to get started!