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OSHA 1910.29

Fall protection system criteria

Subpart D

40 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.29(a)(1), what must an employer ensure about fall protection systems and personal fall protection systems?

Employers must ensure non‑personal fall protection systems meet the criteria in 1910.29 and that personal fall protection systems meet the requirements in Subpart I. See 1910.29(a)(1) and the related 1910.29(a).

  • This means fixed systems like guardrails, covers, and toeboards must follow the specifications in 1910.29.
  • Body belts, harnesses, and related components must comply with 1910.140, as referenced in 1910.29(j).

(Reference: 1910.29(a)(1) and 1910.140.)

Under 1910.29(a)(2), when must an employer provide and install required fall protection systems or falling object protection?

An employer must provide and install any fall protection or falling object protection required by the subpart before any employee begins work that necessitates it. See 1910.29(a)(2).

  • Put simply: you must have the protection in place and comply with the other subpart requirements before employees start the hazardous work.

(Reference: 1910.29(a)(2).)

Under 1910.29(b)(1), what is the required height for the top edge of a guardrail system?

The top edge of top rails (or equivalent guardrail members) must be 42 inches (107 cm), plus or minus 3 inches (8 cm) above the walking‑working surface. See 1910.29(b)(1).

  • The top edge may be higher than 45 inches (114 cm) only if the guardrail still meets all other criteria in paragraph (b).

(Reference: 1910.29(b)(1).)

Under 1910.29(b)(2), what are the options and spacing requirements for intermediate members (midrails, screens, vertical members) in guardrail systems?

Guardrail systems must have intermediate protection when no wall or parapet at least 21 inches high exists; options are midrails, screens/mesh, intermediate vertical members, solid panels, or equivalent members with specific spacing rules in 1910.29(b)(2).

  • Midrails must be installed midway between the top rail and walking surface [1910.29(b)(2)(i)].
  • Screens or mesh must extend from the walking surface to the top rail across the entire opening [1910.29(b)(2)(ii)].
  • Intermediate vertical members (e.g., balusters) must be no more than 19 inches (48 cm) apart [1910.29(b)(2)(iii)].
  • Other equivalent members must ensure openings are not more than 19 inches (48 cm) wide [1910.29(b)(2)(iv)].

(Reference: 1910.29(b)(2)).

Under 1910.29(b)(3) and (4), what load must guardrails withstand and what deflection limit applies when a 200‑pound downward force is applied?

Guardrail top rails must withstand at least a 200‑pound (890 N) force applied downward or outward, and when that 200‑pound downward test is applied the top rail must not deflect to less than 39 inches (99 cm) above the walking surface. See 1910.29(b)(3) and 1910.29(b)(4).

  • This is a strength and performance requirement intended to ensure the rail both resists load and limits downward movement.

(Reference: 1910.29(b)(3) and 1910.29(b)(4).)

Under 1910.29(b)(5), what strength requirement applies to midrails, screens, and other intermediate members?

Midrails, screens, mesh, intermediate verticals, solid panels, and equivalent intermediate members must withstand at least 150 pounds (667 N) applied downward or outward without failure. See 1910.29(b)(5).

  • This ensures intermediate elements provide meaningful protection against employee falls or ejection of objects.

(Reference: 1910.29(b)(5).)

Under 1910.29(b)(6)–(9), what surface, end, and material characteristics are required for top rails and midrails?

Top rails and midrails must be smooth‑surfaced to prevent cuts or snagging, must not overhang terminal posts in a way that creates projection hazards, steel and plastic banding are prohibited, and rails must be at least 0.25 inches (0.6 cm) in diameter or thickness. See 1910.29(b)(6), 1910.29(b)(7), 1910.29(b)(8), and 1910.29(b)(9).

  • Smooth surfaces reduce puncture/laceration risk and clothing snag hazards.
  • Avoid overhangs that create tripping or projection hazards.
  • Do not use steel or plastic banding as rails.

(Reference: 1910.29(b)(6)–(9)).

Under 1910.29(b)(10), how should guardrails be handled at hoist areas when hoisting operations are not underway?

At hoist areas, a removable guardrail section (top rail and midrail) must be placed across the access opening when employees are not performing hoisting operations; chains or gates may be used if they provide an equivalent level of safety. See 1910.29(b)(10).

  • Ensure any substitute (chain/gate) demonstrably provides safety equivalent to guardrails.

(Reference: 1910.29(b)(10).)

Under 1910.29(b)(11)–(12), what are the guardrail requirements when the guardrail surrounds holes or holes used to pass materials?

Guardrail systems around holes must be installed on all unprotected sides or edges of the hole, and for holes through which materials may be passed you may not remove more than two sides of guardrail while materials are being passed; when materials are not being passed the hole must be guarded on all unprotected sides or closed with a cover. See 1910.29(b)(11) and 1910.29(b)(12).

  • Keep openings protected except for the minimum necessary sides during material transfer.

(Reference: 1910.29(b)(11)–(12).)

Under 1910.29(b)(13), how must guardrail openings for ladderway access be configured?

Guardrail openings that serve as points of access (like ladderways) must either have a self‑closing sliding or swinging gate equipped with top and midrails meeting paragraph (b) requirements, or be offset to prevent walking or falling into the hole. See 1910.29(b)(13).

  • A self‑closing gate must slide or swing away from the hole and meet the guardrail strength and height rules.
  • Offsetting means the walkway/landing is arranged so someone cannot walk straight into the hole.

(Reference: 1910.29(b)(13)(i)–(ii).)

Under 1910.29(c), what standard must safety net systems meet?

Safety net systems must meet the requirements in 29 CFR part 1926, Subpart M. See 1910.29(c).

  • Employers using safety nets should consult 29 CFR 1926 Subpart M for design, installation, inspection, and testing criteria.

(Reference: 1910.29(c) and 1926 Subpart M).

Under 1910.29(d)(1) and (d)(2), what are the employer requirements for designated areas and warning lines?

When using a designated area, employers must ensure employees remain inside it while work is underway and that the perimeter is delineated by a warning line meeting the criteria in 1910.29(d)(2) and (d)(3). See 1910.29(d)(1) and 1910.29(d)(2).

  • Warning lines must have at least a 200‑pound breaking strength, be 34–39 inches above the surface, be clearly visible at 25 feet, be erected as close to the work as task permits, and be placed at required distances from the roof edge based on the work frequency [1910.29(d)(2)].

(Reference: 1910.29(d)(1)–(2)).

Under 1910.29(d)(2)(vi) and (d)(3), what distances must warning lines be placed from the roof edge for different types of work and when mobile equipment is used?

Warning lines must be at least 6 feet (1.8 m) from the roof edge for work that is temporary and infrequent, but at least 15 feet (4.6 m) for other work; when mobile mechanical equipment is used for temporary/infrequent work the line must be at least 6 feet parallel and 10 feet perpendicular to the unprotected edge. See 1910.29(d)(2)(vi) and 1910.29(d)(3).

  • These distances increase the margin of safety when equipment or longer-duration tasks raise fall risk.

(Reference: 1910.29(d)(2)(vi) and 1910.29(d)(3).)

Under 1910.29(e), what are the strength and securing requirements for covers over holes in walking‑working surfaces?

Covers must support at least twice the maximum intended load without failure and be secured to prevent accidental displacement. See 1910.29(e)(1)–(2).

  • Marking and secure fastening are common practices to prevent displacement and unauthorized removal.

(Reference: 1910.29(e)(1)–(2).)

Under 1910.29(f)(1)(ii), what are the minimum heights for stair rail systems installed before and on/after January 17, 2017?

Stair rail systems installed before January 17, 2017 must be at least 30 inches (76 cm) high from the leading edge of the tread to the top surface of the top rail; systems installed on or after January 17, 2017 must be at least 42 inches (107 cm) high. See 1910.29(f)(1)(ii)(A) and 1910.29(f)(1)(ii)(B).

  • Be sure to measure from the leading edge of the stair tread to the top surface of the top rail when checking compliance.

(Reference: 1910.29(f)(1)(ii)(A)–(B).)

Under 1910.29(f)(1)(iii), when can the top rail of a stair rail serve as the handrail?

The top rail may serve as a handrail only when the stair rail height is between 36 inches (91 cm) and 38 inches (97 cm) measured at the leading edge of the tread, and the top rail meets the other handrail requirements in paragraph (f). See 1910.29(f)(1)(iii)(A)–(B).

  • In other words, combination stair rail/handrail is allowed only within that narrow height range and meeting all other handrail criteria.

(Reference: 1910.29(f)(1)(iii).)

Under 1910.29(f)(2) and (f)(3), what are the finger clearance and surface requirements for handrails?

Handrails must have at least 2.25 inches (5.7 cm) clearance between the rail and any other object, and must be smooth‑surfaced to prevent punctures, lacerations, and snagging. See 1910.29(f)(2) and 1910.29(f)(3).

  • Ensure adequate hand grip space and a smooth finish so clothing doesn’t catch and hands aren’t injured.

(Reference: 1910.29(f)(2)–(3).)

Under 1910.29(f)(4)–(7), what are opening, handhold, projection, and strength requirements for stair rails and handrails?

No opening in a stair rail may exceed 19 inches (48 cm); handrails must be shaped and sized for a firm grasp; ends must not present projection hazards; and handrails/top rails must withstand at least a 200‑pound (890 N) force applied downward or outward without failure. See 1910.29(f)(4)–(7).

  • These combined requirements ensure safe grip, limit fall or entrapment openings, avoid sharp projections, and require structural strength.

(Reference: 1910.29(f)(4)–(7).)

Under 1910.29(g), what design and platform size requirements apply to cages, wells, and platforms used with fixed ladders?

Cages and wells must permit easy access/egress, be continuous along the ladder except at transfer points, be designed to contain and direct employees in the event of a fall, and platforms used with fixed ladders must provide at least a 24 by 30 inch horizontal surface. See 1910.29(g)(1)–(4).

  • These features are intended to reduce fall impact and help safe transfer between ladder and landing.

(Reference: 1910.29(g)(1)–(4).)

Under 1910.29(h), what special requirements apply to outdoor advertising employees who climb fixed ladders without fall protection?

Outdoor advertising employers must ensure employees who climb fixed ladders without fall protection are physically capable, have completed appropriate training or apprenticeship with hands‑on ladder training and are retrained as needed, can demonstrate safe climbing skills, and perform climbing as part of routine work. See 1910.29(h).

  • These provisions are limited to employers engaged in outdoor advertising operations as referenced in 1910.28(b)(10).

(Reference: 1910.29(h).)

Under 1910.29(i), what are the key performance and installation criteria for ladder safety systems?

Ladder safety systems must allow employees to climb using both hands without continuously manipulating the system, limit the harness/attachment connection to 9 inches or less, have proper mountings spaced to provide fall‑stopping strength, use cable guides for flexible carriers spaced 25–40 feet apart, not reduce the ladder’s design strength, and pass an 18‑inch drop test of a 500‑pound weight. See 1910.29(i)(1)–(6).

  • These rules ensure ladder safety systems are both usable and structurally capable of arresting a fall.

(Reference: 1910.29(i).)

Under 1910.29(j) and 1910.140, what standard applies to body belts, harnesses, and components used in personal fall arrest, work positioning, and travel restraint systems?

Body belts, harnesses, and other components used in personal fall arrest systems, work‑positioning systems, and travel‑restraint systems must comply with [1910.140]. See 1910.29(j) and 1910.140.

  • Employers should use equipment tested and certified to meet the requirements in [1910.140].

(Reference: 1910.29(j) and 1910.140).

Under 1910.29(k)(1), what are the required dimensions and strength for toeboards used for falling object protection?

Toeboards must be erected along exposed edges for a sufficient length to protect employees below, have a minimum vertical height of 3.5 inches (9 cm) from the toeboard top to the walking‑working surface, have no more than 0.25‑inch clearance above the walking surface, be solid or have openings no larger than 1 inch (3 cm), and must withstand at least a 50‑pound (222 N) force downward or outward. See 1910.29(k)(1)(i)–(vi).

  • A reduced 2.5‑inch minimum can apply around vehicle pits when a taller toeboard would block vehicle access, but the employer must justify omission in those pits [1910.29(k)(1)(v)].

(Reference: 1910.29(k)(1).)

Under 1910.29(k)(2), when must an employer install paneling or screening between toeboards and guardrails?

If tools, equipment, or materials are piled higher than the toeboard, the employer must install paneling or screening from the toeboard to the midrail for a sufficient length to protect employees below; if piled above the midrail, paneling/screening must extend to the top rail. See 1910.29(k)(2)(i).

  • Also ensure all openings in guardrail systems are small enough to prevent falling objects [1910.29(k)(2)(ii)].

(Reference: 1910.29(k)(2).)

Under 1910.29(k)(3), what are the requirements for canopies used as falling object protection?

Canopies used for falling object protection must be strong enough to prevent collapse and to prevent penetration by falling objects. See 1910.29(k)(3).

  • Design canopies to carry expected loads and to stop small and large falling objects without failure.

(Reference: 1910.29(k)(3).)

Under 1910.29(l), what size, clearance, and strength requirements apply to grab handles?

Grab handles must be at least 12 inches (30 cm) long, mounted to provide at least 3 inches (8 cm) of clearance from the framing or opening, and be capable of withstanding a maximum horizontal pull‑out force equal to two times the maximum intended load or 200 pounds (890 N), whichever is greater. See 1910.29(l)(1)–(3).

  • This ensures grab handles can be gripped and will stay secured under expected loads.

(Reference: 1910.29(l).)

Under 1910.29(b)(13)(i)–(ii), what are acceptable means to prevent a worker from falling into a ladderway opening used for access?

Acceptable means are a self‑closing gate that slides or swings away from the hole and has top and midrails meeting paragraph (b), or an offset arrangement that prevents an employee from walking or falling into the hole. See 1910.29(b)(13)(i)–(ii).

  • The gate must meet the same guardrail strength and height criteria as other guardrails.

(Reference: 1910.29(b)(13)(i)–(ii).)

How does OSHA interpret fall protection needs for an HVAC technician stepping off a portable ladder onto a low slope roof and walking to equipment 25 feet from the edge? (Letter of Interpretation)

OSHA has interpreted that stepping from a portable ladder onto a low‑slope roof and walking to work 25 feet from the edge does not itself require fall protection, although other work performed within 15 feet of the roof edge may. See the Letter of Interpretation on Fall protection on low slope roofs and 1910.29(b)(13)(iii).

  • In short: no specific OSHA rule requires fall protection just to step off a ladder and walk to a point 25 feet from the edge, but work performed within 15 feet of the edge may trigger guardrail or other protection requirements.

(Reference: OSHA Letter of Interpretation: Fall protection on low slope roofs and 1910.29(b)(13)(iii).)

Per the Letter of Interpretation dated 2024‑06‑06‑0, does the top rail on a mobile ladder stand platform need to meet the 200‑pound load requirement in 1910.29(b)(3)?

Yes — OSHA confirms that guardrails and top rails on mobile ladder stand platforms must meet the same 200‑pound strength requirement applicable to guardrail systems in 1910.29(b)(3). See the Mobile Ladder Stand Requirements Letter of Interpretation and 1910.29(b)(3).

  • The Letter of Interpretation clarifies that mobile platform rails must be designed to resist the same test loads as other guardrails. See Mobile ladder stand requirements.

(Reference: OSHA Letter of Interpretation: Mobile ladder stand requirements and 1910.29(b)(3).)

Per the Letter of Interpretation dated 2024‑10‑17, how should stair width be measured relative to handrails and vertical barriers?

OSHA interprets that stair width required by 29 CFR 1910.25(c)(4) is measured between vertical barriers (walls, stair rails, guardrails) and that handrails are not considered vertical barriers or obstructions for measuring stair width. See the Stair Width Measurement Guidance Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17 and the referenced standard 1910.

  • Practically: you measure stair clear width between vertical barriers; handrails do not reduce the required width measurement.

(Reference: OSHA Letter of Interpretation: Stair width measurement guidance and 1910.25(c)(4) as discussed.)

Under 1910.29(d)(2)(i)–(iv), what visibility and support characteristics must warning lines have?

Warning lines must have a minimum 200‑pound breaking strength, be installed so the lowest point (including sag) is 34–39 inches above the surface, be supported so pulling one section doesn't slack adjacent sections below those limits, and be clearly visible from 25 feet away anywhere within the designated area. See 1910.29(d)(2)(i)–(iv).

  • Use visible materials and stable supports to maintain height and sightlines at all times.

(Reference: 1910.29(d)(2).)

Under 1910.29(i)(2) and (i)(6), what maximum connection length and drop test must ladder safety systems meet?

The connection between the carrier or lifeline and the body harness or belt must not exceed 9 inches (23 cm), and ladder safety systems and supports must withstand an 18‑inch drop test of a 500‑pound (227‑kg) weight without failure. See 1910.29(i)(2) and 1910.29(i)(6).

  • These requirements help ensure the system will arrest a fall promptly and that the attachment does not add slack that increases fall distance.

(Reference: 1910.29(i)(2),(6).)

Under 1910.29(b)(12)(i) when passing materials through a guarded hole, how many sides of the guardrail may be removed?

When materials are being passed through a hole, not more than two sides of the guardrail system may be removed. See 1910.29(b)(12)(i).

  • Remove only the minimum necessary sections during active material transfer and restore protection when done.

(Reference: 1910.29(b)(12)(i).)

Under 1910.29(b)(14), are guardrail systems required on ramps and runways?

Yes — guardrail systems on ramps and runways must be installed along each unprotected side or edge. See 1910.29(b)(14).

  • Ensure continuous protection along exposed sides to prevent falls.

(Reference: 1910.29(b)(14).)

Under 1910.29(b)(15), how often should manila or synthetic rope used as top or midrails be inspected?

Manila or synthetic rope used for top rails or midrails must be inspected as necessary to ensure the rope continues to meet the strength requirements of paragraphs (b)(3) and (b)(5). See 1910.29(b)(15).

  • Inspect frequently and replace rope showing wear, degradation, or damage that could reduce strength below specified test loads.

(Reference: 1910.29(b)(15).)

Under 1910.29(k)(2)(ii), what must employers ensure about openings in guardrail systems related to falling object protection?

Employers must ensure all openings in guardrail systems are small enough to prevent objects from falling through the opening. See 1910.29(k)(2)(ii).

  • Use mesh, panels, or closer spacing of intermediate members when loose objects could fall through otherwise.

(Reference: 1910.29(k)(2)(ii).)

Under 1910.29(k)(1)(v), when may toeboards be omitted around vehicle repair pits?

Toeboards may be omitted around vehicle repair, service, or assembly pits when the employer demonstrates that a toeboard would prevent access to a vehicle that is over the pit; otherwise toeboards used around pits must be at least 2.5 inches (6 cm) high. See 1910.29(k)(1)(v).

  • Document and be prepared to justify the demonstration to an inspector or auditor.

(Reference: 1910.29(k)(1)(v).)

Under 1910.29(b) note, where are the guardrail criteria for scaffolds found?

The note to paragraph (b) states that criteria and practices for guardrail systems on scaffolds are contained in 29 CFR part 1926, Subpart L. See the note in 1910.29(b) and 1926 Subpart L.

  • Scaffold guardrail requirements differ and are addressed in the construction‑industry rules in [1926 Subpart L].

(Reference: 1910.29(b) note and 1926 Subpart L).

Under 1910.29(f)(1)(i), what is the required handrail height range measured from the leading edge of the stair tread?

Handrails must be not less than 30 inches (76 cm) and not more than 38 inches (97 cm) from the leading edge of the stair tread to the top surface of the handrail. See 1910.29(f)(1)(i).

  • This is the required vertical range for conventional handrails (separate from stair rail systems installed on/after 2017).

(Reference: 1910.29(f)(1)(i).)

Under 1910.29(c) and the referenced standard, who should employers consult for safety net design and installation criteria?

Employers must consult 29 CFR part 1926, Subpart M for safety net system design, installation, inspection, and testing criteria. See 1910.29(c) and 1926 Subpart M.

  • Follow the detailed requirements in Subpart M to ensure nets are properly rated and installed.

(Reference: 1910.29(c) and 1926 Subpart M).