OSHA Begins 90 Day Phase-In of New Fall Protection Requirements

Last December, OSHA rescinded its Interim Fall Protection Compliance Guidelines for Residential Construction, which had been in place since 1995.  Effective June 16, 2011, employers must provide conventional fall protection systems - to protect all employees engaged in residential construction activities 6 feet or more above a lower level.  The new Compliance Guidance for Residential Construction will require employers to follow OSHA's Subpart M Fall Protection regulation, which allows the flexibility of using a written fall protection plan and alternative fall protection procedures when conventional systems are either infeasible or using them creates greater hazard.
 
Specifically, the new guidelines clarify OSHA's citation policy with regard to the requirement that employers engaged in residential construction demonstrate the infeasibility of required fall protection systems, or that such systems create a greater hazard, prior to implementing alternative measures. This guideline also clarifies OSHA's enforcement policy regarding the requirements that fall protection plans, when used, be written and site-specific.
 
Importantly, OSHA has indicated a 90-day phase: For the first three months that the new directive is in effect, OSHA field staff will refrain from issuing fall protection citations to employers who are using the protective measures in the old directive. Instead, during this period, field staff will focus on helping employers come into compliance with the new directive. However, during this time, OSHA will continue to cite residential construction employers that are not, at a minimum, adhering to the alternative protective measures that were set forth in the old fall protection directive.
 
The OSHA guideline may be found here.
The OSHA letter to NAHB outlining the 90-day phase-in may be found here.
Additional resources are available from NAHB, including a fact sheet showing the changes made from the old to the new guidelines.

Please contact your local Sanford & Hawley Yard Manager or Sales Representative for details on the selection of fall protection products offered.