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OSHA 1910.28

Fall and falling object protection

Subpart D

42 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.28(b)(1), when is fall protection required for employees working on a walking-working surface with an unprotected side or edge?

Under 1910.28(b)(1), fall protection is required whenever an employee is on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level. Employers must protect those employees by using one or more of the following: a guardrail system, a safety net system, or a personal fall protection system such as a personal fall arrest, travel restraint, or positioning system. See the requirement in 1910.28(b)(1)(i) and the general duty to provide fall protection in 1910.28(a).

Under 1910.28(a)(2), does the fall protection rule apply when an employee is inspecting or assessing workplace conditions before work begins?

Under 1910.28(a)(2), the fall protection rule generally does not apply when employers are inspecting, investigating, or assessing workplace conditions or the work to be performed prior to the start of work or after all work has been completed. However, this exemption does not apply if fall protection systems meeting 1910.29 have already been installed and are available for use during those inspections. See 1910.28(a)(2).

Under 1910.28(b)(3)(i), how must employers protect employees from falling through holes (including skylights) that are 4 feet or more above a lower level?

Under 1910.28(b)(3)(i), employers must protect employees from falling through any hole (including skylights) that is 4 feet (1.2 m) or more above a lower level by using one or more of the following: covers, guardrail systems, travel restraint systems, or personal fall arrest systems. See 1910.28(b)(3)(i) and the applicable design criteria in 1910.29.

Under 1910.28(b)(1)(ii), when can an employer use a fall protection plan on residential roofs instead of guardrails, nets, or personal fall protection systems?

Under 1910.28(b)(1)(ii), an employer may use a fall protection plan for work on residential roofs only when the employer can demonstrate that use of guardrails, safety nets, or personal fall protection systems is not feasible or would create a greater hazard. The employer must develop and implement a fall protection plan that meets the requirements of 29 CFR 1926.502(k) and provide training that meets 29 CFR 1926.503(a) and (c). Note there is a presumption that using at least one of the systems in 1910.28(b)(1)(i) is feasible and will not create a greater hazard, so the employer has the burden to justify the plan. See 1910.28(b)(1)(ii).

Under 1910.28(b)(2), what fall protection must be used in hoist areas when employees are 4 feet or more above a lower level?

Under 1910.28(b)(2)(i), each employee in a hoist area who is 4 feet (1.2 m) or more above a lower level must be protected from falling by either a guardrail system, a personal fall arrest system, or a travel restraint system. Additionally, if a guardrail, gate, or chain is removed and an employee must lean through the access opening to facilitate hoisting, the employee must be protected by a personal fall arrest system. See 1910.28(b)(2).

Under 1910.28(b)(3)(v)(A), how must hatchway and chute-floor holes be protected when not in use?

Under 1910.28(b)(3)(v)(A), hatchway and chute-floor holes must be protected by a hinged floor-hole cover that meets the criteria in 1910.29 and a fixed guardrail system that leaves only one exposed side; when the hole is not in use, the employer must ensure the cover is closed or a removable guardrail system is provided on the exposed sides. See 1910.28(b)(3)(v)(A).

Under 1910.28(b)(4)(ii), when are guardrails or handrails not required on dockboards?

Under 1910.28(b)(4)(ii), guardrails or handrails are not required on dockboards when all three conditions are met: (A) dockboards are used solely for materials-handling operations with motorized equipment; (B) employees engaged in these operations are not exposed to fall hazards greater than 10 feet (3 m); and (C) those employees have been trained according to 1910.30. See 1910.28(b)(4)(ii).

Under 1910.28(b)(5)(ii), when can an employer omit guardrails on one side of a narrow runway used for a special purpose?

Under 1910.28(b)(5)(ii), an employer may omit the guardrail on one side of a runway used exclusively for a special purpose if they can show it is not feasible to have guardrails on both sides and they ensure the runway is at least 18 inches (46 cm) wide and each employee is provided with and uses a personal fall arrest system or a travel restraint system. See 1910.28(b)(5)(ii).

Under 1910.28(b)(6), how must employers protect employees working above dangerous equipment?

Under 1910.28(b)(6), employers must protect employees who are less than 4 feet (1.2 m) above dangerous equipment from falling into or onto that equipment by using a guardrail system or a travel restraint system unless the equipment is covered or guarded to eliminate the hazard. If employees are 4 feet (1.2 m) or more above dangerous equipment, employers must protect them by using guardrail systems, safety net systems, travel restraint systems, or personal fall arrest systems. See 1910.28(b)(6).

Under 1910.28(b)(7), what protection is required when working near an opening whose inside bottom edge is less than 39 inches above the walking surface and outside bottom edge is 4 feet or more above a lower level?

Under 1910.28(b)(7), employees on a walking-working surface near such an opening must be protected from falling by using guardrail systems, safety net systems, travel restraint systems, or personal fall arrest systems. See 1910.28(b)(7).

Under 1910.28(b)(8), when is fall protection not required for repair, service, or assembly pits less than 10 feet deep, and what controls must the employer use?

Under 1910.28(b)(8), fall protection is not required for repair, service, or assembly pits less than 10 feet (3 m) deep provided the employer limits access within 6 feet (1.8 m) of the pit edge to authorized employees trained per 1910.30, applies contrasting floor markings at least 6 feet from the edge, or places a warning line and stanchions (capable of resisting a 16-pound horizontal force at 30 inches) or a combination of markings and warning lines. When multiple pits are close together, the employer may place contrasting floor markings around the entire area. See 1910.28(b)(8) and [1910.145] (for sign requirements) at 1910.145.

Under 1910.28(b)(9)(i), what fall protection must be provided on fixed ladders that extend more than 24 feet above a lower level?

Under 1910.28(b)(9)(i), for fixed ladders extending more than 24 feet (7.3 m) above a lower level, employers must ensure: (A) existing fixed ladders installed before November 19, 2018 are equipped with a personal fall arrest system, ladder safety system, cage, or well; and (B) new fixed ladders installed on or after November 19, 2018 are equipped with a personal fall arrest system or a ladder safety system. See 1910.28(b)(9)(i)(A)–(B).

Under 1910.28(b)(3)(iv), how must ladderway floor holes or ladderway platform holes be protected?

Under 1910.28(b)(3)(iv), ladderway floor holes and ladderway platform holes must be protected on all exposed sides by a guardrail system and toeboards, except at the entrance to the hole where a self-closing gate or an offset must be used. See 1910.28(b)(3)(iv).

Under 1910.28(b)(3)(v)(B), what are acceptable protections for a hatchway or chute-floor hole when passing materials?

Under 1910.28(b)(3)(v)(B), acceptable protections for hatchway or chute-floor holes when passing materials include a removable guardrail system and toeboards on not more than two sides of the hole with a fixed guardrail system on all other exposed sides. The removable guardrail system must be kept in place when the hole is not in use. See 1910.28(b)(3)(v)(B)–(C).

Under 1910.28(a)(2)(i) and (ii), are portable ladders covered by the fall protection requirements in 1910.28?

Under 1910.28(a)(2)(i), portable ladders are exempt from the scope of 1910.28; however, employers must still follow the ladder requirements found elsewhere in 1910. The exemption in 1910.28(a)(2)(ii) for pre- and post-work inspections also exists as described in the standard. For portable-ladder specific requirements see the ladder standards in 1910.

Under 1910.28(b)(3)(ii), how must employers protect employees from tripping into holes less than 4 feet above a lower level?

Under 1910.28(b)(3)(ii), employers must protect employees from tripping into or stepping into any hole that is less than 4 feet (1.2 m) above a lower level by using covers or guardrail systems. The covers and guardrails must meet the design criteria in 1910.29. See 1910.28(b)(3)(ii).

Subject: fall protection on low-slope roofs — does an employee need fall protection just because they step from a portable ladder onto a low-slope roof and walk to work 25 feet from the edge?

Subject: low-slope roofs — No, stepping off a portable ladder onto a low-slope roof and walking directly to a work area 25 feet from the edge does not by itself require fall protection under these standards. OSHA has clarified that fall protection is not specifically required in that scenario, but when work is performed within 15 feet of the roof edge or if the work is not infrequent/temporary, fall protection rules in 1910.28(b)(13)(i) or (iii) may apply. See OSHA's letter of interpretation about fall protection on low-slope roofs at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1 and 1910.28.

Under 1910.28(b)(3)(v)(A), what design criteria must hinged floor-hole covers meet?

Under 1910.28(b)(3)(v)(A), hinged floor-hole covers must meet the criteria in 1910.29, which sets strength, marking, and installation requirements for covers so they can support expected loads and prevent falls. See 1910.28(b)(3)(v)(A) and the design rules in 1910.29.

Under 1910.28(b)(3)(v)(C), when is a guardrail or travel restraint acceptable when passing material through a hatchway?

Under 1910.28(b)(3)(v)(C), when work operations necessitate passing material through a hatchway or chute-floor hole, the employer may protect employees by using either a guardrail system or a travel restraint system. The chosen system must meet the applicable criteria in 1910.29. See 1910.28(b)(3)(v)(C).

Under 1910.28(b)(2)(iii), do grab handles at hoist areas have to meet any specific criteria?

Under 1910.28(b)(2)(iii), if grab handles are installed at hoist areas they must meet the requirements of 1910.29(l), which includes strength and installation criteria for grab handles and similar attachments. See 1910.28(b)(2)(iii).

Under 1910.28(b)(3)(v)(B), what must an employer do with removable guardrail systems when the hatch is not in use?

Under 1910.28(b)(3)(v)(B), the employer must keep the removable guardrail system in place when the hatchway or chute-floor hole is not in use. If the cover is removed for use, the employer must provide the required removable guardrails and toeboards on appropriate sides. See 1910.28(b)(3)(v)(B)–(C).

Subject: head protection for crane operators — when is head protection required and what standards apply?

Subject: head protection for crane operators — Employers must require crane operators and other employees to wear protective helmets when there is a potential for head injury from falling objects (for example, lifting a load with a crane or hoist). Head protection must comply with applicable ANSI helmet standards incorporated by reference in 1910.135(b)(1). OSHA specifically confirmed this application to crane work in a letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2, and you should also consider crane-specific rules in 1910.179.

Subject: mobile ladder stand platforms — what top-rail strength requirement applies to guardrails and where is it found?

Subject: mobile ladder stand platforms — Top rails on guardrail systems must be able to withstand, without failure, a force of at least 200 pounds (890 N) applied downward or outward within 2 inches of the top edge at any point along the top rail. This strength requirement is in 1910.29(b)(3) and is explained in OSHA's letter of interpretation about mobile ladder stand requirements at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.

Under 1910.28(b)(9), when I replace a section of a fixed ladder with a new section that used to have a cage or well, do I have to install a personal fall arrest system or ladder safety system in that replaced section?

Yes. When a fixed ladder, cage, or well (or any portion of a section) is replaced, you must install a personal fall arrest system or ladder safety system in at least that replaced section. This is expressly required under 1910.28(b)(9), including the provision at 1910.28(b)(9)(i)(D).

Under 1910.28(b)(9), is there a final deadline by which all fixed ladders must be equipped with a personal fall arrest system or ladder safety system?

Yes. The standard sets a final deadline: on and after November 18, 2036, all fixed ladders must be equipped with either a personal fall arrest system or a ladder safety system, as stated in 1910.28(b)(9)(i)(D).

Under 1910.28(b)(9)(ii), if a one-section fixed ladder is equipped with a ladder safety or personal fall arrest system, what must the employer ensure about protection and rest platforms?

The employer must ensure the system protects the entire vertical distance of the ladder and that rest platforms are provided at required intervals. Specifically, 1910.28(b)(9)(ii)(A) requires protection throughout the ladder's vertical distance, and 1910.28(b)(9)(ii)(B) requires rest platforms at maximum intervals of 150 feet (45.7 m).

Under 1910.28(b)(9)(iii), what must employers do for ladder sections that have a cage or well?

Employers must offset ladder sections from adjacent sections and provide landing platforms at required intervals. The rule says ladder sections with a cage or well must be offset from adjacent sections per 1910.28(b)(9)(iii)(A) and must have landing platforms at maximum intervals of 50 feet (15.2 m) per 1910.28(b)(9)(iii)(B).

Under 1910.28(b)(9)(iv), can I keep a cage or well on a ladder if I install a ladder safety system or personal fall arrest system?

Yes—provided the cage or well does not interfere with the safe operation of the ladder safety system or personal fall arrest system. The standard allows using a cage or well in combination with those systems so long as it does not interfere, per 1910.28(b)(9)(iv).

Under 1910.28(b)(10)(ii), what special requirements apply to employees doing outdoor advertising (billboards) who climb a fixed ladder installed before November 19, 2018 that has no cage, well, or ladder safety system?

If an employee climbs a pre-11/19/2018 fixed ladder that lacks a cage, well, personal fall arrest system, or ladder safety system, the employer must: (1) ensure the employee receives training and demonstrates the physical capability to climb in accordance with 1910.29(h) as required by 1910.28(b)(10)(ii)(A); (2) require the employee to wear a body harness with an 18-inch (46 cm) rest lanyard per 1910.28(b)(10)(ii)(B); (3) keep both hands free of tools/materials while climbing per 1910.28(b)(10)(ii)(C); and (4) ensure the employee is protected by a fall protection system once they reach the work position per 1910.28(b)(10)(ii)(D).

Under 1910.28(b)(11)(i), when must employees exposed to an unprotected stairway landing be protected by a guardrail or stair rail system?

Under 1910.28(b)(11)(i), each employee exposed to an unprotected side or edge of a stairway landing that is 4 feet (1.2 m) or more above a lower level must be protected by a guardrail or stair rail system. See 1910.28(b)(11)(i).

Under 1910.28(b)(11)(ii) and the 2024 LOI 'Stair width measurement guidance', how do I measure stair width for handrail requirements—do handrails reduce the required width?

Measure stair width between the vertical barriers, and handrails are not treated as vertical barriers that reduce the required width. The handrail requirements are in 1910.28(b)(11)(ii), and OSHA clarified in the Stair width measurement guidance that stair width is measured between vertical barriers (like walls or stair rails) and that handrails are not considered obstructions for that measurement.

Under 1910.28(b)(11)(iii), what are the handrail requirements for ship stairs and alternating tread type stairs?

Under 1910.28(b)(11)(iii), ship stairs and alternating-tread-type stairs must be equipped with handrails on both sides.

Under 1910.28(b)(12), what fall protection is required for employees using rope descent systems 4 feet or more above a lower level?

Employees using a rope descent system 4 feet (1.2 m) or more above a lower level must be protected from falling by a personal fall arrest system, as required by 1910.28(b)(12)(ii).

Under 1910.28(b)(13), when is fall protection required for work on low-slope roofs?

It depends on how close the work is to the roof edge. If work is performed less than 6 feet (1.6 m) from the roof edge, each employee must be protected by a guardrail, safety net, travel restraint, or personal fall arrest system per 1910.28(b)(13)(i). Work performed at least 6 feet but less than 15 feet (1.6–4.6 m) from the edge requires one of those protections or a designated area per 1910.28(b)(13)(ii). For work 15 feet (4.6 m) or more from the edge, employers may be able to use a designated area or no fall protection if the work is both infrequent and temporary and a work rule is enforced; see 1910.28(b)(13)(iii). This framework is further explained in OSHA's letter of interpretation on fall protection for low-slope roofs in Fall protection on low slope roofs.

Referring to the 2024 LOI 'Fall protection on low slope roofs', if an employee climbs a portable ladder onto a low-slope roof and walks 25 feet from the edge to their work, do they need fall protection while walking to the HVAC unit?

No. OSHA does not require fall protection for an employee who steps off a portable ladder onto a low-slope roof and walks directly to a work area 25 feet from the edge. The Fall protection on low slope roofs letter explains that fall protection is not specifically required in that scenario, though protections may be required when actual work is being performed near the edge per 1910.28(b)(13).

Under 1910.28(b)(14)(i), what fall protection must slaughtering facility platforms use when an employee is on the unprotected working side 4 feet or more above a lower level?

Employees on the unprotected working side of a slaughtering facility platform 4 feet (1.2 m) or more above a lower level must be protected by either guardrail systems or travel restraint systems, as required by 1910.28(b)(14)(i).

Under 1910.28(b)(14)(ii), can work be done without a guardrail or travel restraint system when use of those systems is infeasible, and what conditions must the employer meet?

Yes—only if the employer can demonstrate use is infeasible and meets strict conditions: (A) the work operation for which fall protection is infeasible must be in process; (B) access to the platform must be limited to authorized employees; and (C) the authorized employees must be trained in accordance with [1910.30], as outlined in 1910.28(b)(14)(ii).

Under 1910.28(b)(15), what protections must an employer provide for walking-working surfaces 4 feet or more above a lower level when the surface isn't covered elsewhere in the section?

For walking-working surfaces 4 feet (1.2 m) or more above a lower level not otherwise addressed, the employer must protect employees by using guardrail systems, safety net systems, or personal fall protection systems (such as personal fall arrest, travel restraint, or positioning systems), according to 1910.28(b)(15).

Under 1910.28(c) and related subsections, what methods can an employer use to protect employees from falling objects?

The employer must ensure affected employees wear head protection that meets subpart I, and must also implement one or more engineering or administrative measures to prevent falling objects. Specifically, head protection is required under 1910.28(c). In addition, employers must: erect toeboards, screens, or guardrails to keep objects from falling (1910.28(c)(1)); erect canopies or keep objects away from edges/openings (1910.28(c)(2)); or barricade the area below and prohibit entry while keeping objects away from edges/openings (1910.28(c)(3)).

Under 1910.28(c) and the LOI 'Head protection for crane operators', when must crane operators or people working near lifted loads wear head protection?

Employees must wear protective helmets when there is a potential for head injury from falling objects, including when working near crane lifts. OSHA's Head protection for crane operators letter explains that 1910.135(a)(1) requires helmets where there is potential for falling-object head injury, and 1910.28(c) requires protection from falling objects generally. The LOI also notes applicable helmet consensus standards to meet 1910.135(b)(1).

Under 1910.28(b)(9) and related provisions, can an employer combine the use of a cage with a ladder safety system, and what caution does the standard give?

Yes—an employer may combine a cage or well with a personal fall arrest system or ladder safety system only if the cage or well does not interfere with system operation. The rule permits combination but warns that the cage or well must not interfere with the safe operation of the fall protection system per 1910.28(b)(9)(iv).

Under 1910.29 and the LOI 'Mobile ladder stand requirements', what force must a top rail or guardrail withstand on a mobile ladder stand platform?

Top rails or guardrail systems must withstand at least 200 pounds of force applied downward or outward near the top edge. OSHA's guardrail performance requirement is in 1910.29(b)(3), and the Mobile ladder stand requirements letter reiterates that top rails must meet that performance.