Fall protection requirements

Employees must be protected from falling through skylights or other holes more than 6 feet above a lower level by a personal fall arrest system, covers, or guardrail systems.

• A cover used to protect a skylight must meet the cover strength criteria in 29 CFR 1926.502(i) (for example, support at least twice the weight of employees, equipment, and materials that may be imposed at any one time).
• If a skylight itself meets those cover criteria, OSHA will treat it as a compliant cover; otherwise you must provide a compliant cover, guardrail, or personal fall arrest.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation on skylight fall protection, Skylight fall protection criteria.

No — an employer cannot rely solely on a manufacturer's claim that a skylight is "OSHA-compliant" without confirming it meets the standard's cover criteria.

• OSHA does not endorse products; the employer is responsible for ensuring the skylight (as a cover) can support at least twice the maximum expected load per 29 CFR 1926.502(i).
• If the manufacturer's rating does not include a safety factor or if capacity is unclear, employers must obtain more information or use an approved cover, guardrails, or personal fall arrest systems.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Skylight fall protection criteria.

A fall protection plan is only allowed for precast concrete erection when the employer demonstrates that guardrails, safety nets, or personal fall arrest systems are infeasible or would create a greater hazard.

• There is a presumption that at least one conventional fall protection system is feasible and does not create a greater hazard; the employer bears the burden of proving otherwise.
• Appendix E contains sample reasons that may support infeasibility or greater hazard, but Appendix E alone does not substitute for a site-specific demonstration.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation on precast erection, Fall protection for precast erection.

A CAZ is an area where access is limited to authorized workers and alternative fall protection protocols (approved in a fall protection plan) may be used when conventional systems are infeasible or create a greater hazard.

• Use of a CAZ for leading-edge or similar work requires a fall protection plan meeting 29 CFR 1926.502(k) and a demonstration that guardrails, nets, or personal arrest systems are infeasible or more hazardous.
• Employers should follow the guidance and sample reasons in Appendix E when developing a site-specific plan.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation on precast erection, Fall protection for precast erection.

Yes — a conveyance operating in temporary or incomplete guides, suspended by temporary cables, using a temporary hoist machine, or any combination of those temporary devices meets the definition of a suspended scaffold.

• When such conveyances are treated as suspended scaffolds, the scaffold requirements in 29 CFR 1926.451(g) (fall protection for suspended scaffolds) apply, and falling object protections must meet 29 CFR 1926.451(h).
• This interpretation applies even if the conveyance includes a permanent elevator car frame combined with temporary devices.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Scaffold and fall protection clarification.

Workers on suspended scaffolds must use fall protection that complies with the scaffold fall protection provisions in 29 CFR 1926.451(g).

• Typical measures include personal fall arrest systems or guardrails as required by 1926.451(g).
• Overhead protection and falling object protections required by 1926.451(h) must also be provided for suspended scaffold operations.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Scaffold and fall protection clarification.

Covers over holes and skylights must be capable of supporting at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time.

• Covers should be secured so they cannot be displaced by wind, vibration, or other accidental movement.
• Mark covers with "HOLE" or "COVER" or another warning, and ensure they are easily visible to workers.

See 29 CFR 1926 Subpart M and the skylight LOI discussing cover criteria, Skylight fall protection criteria.

Not automatically — you must know whether the manufacturer's rating includes the needed safety factor; if it does not, the allowable load under 1926.502(i)(2) would be half the rated value.

• For example, if the 775-pound rating lacks a safety factor, the effective allowable weight per 1926.502(i)(2) would be 387.5 pounds.
• Employers must verify the rating and ensure the cover will support twice the maximum expected load, or otherwise use compliant covers, guardrails, or personal fall arrest systems.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Skylight fall protection criteria.

OSHA enforces suspended-scaffold requirements (including fall protection and falling object protection) for temporary conveyances that meet the suspended scaffold definition.

• That means employers must comply with 29 CFR 1926.451(g) for fall protection and 1926.451(h) for falling object protection when conveyances are suspended by temporary devices or operate in temporary/incomplete guides.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Scaffold and fall protection clarification.

No — if a permanent elevator car is used with temporary devices (temporary guides, temporary suspension cables, or a temporary hoist) and a temporary working platform, OSHA treats the combination as a suspended scaffold.

• The suspended scaffold provisions in 29 CFR 1926.451(g) and falling object protections in 1926.451(h) apply to these configurations.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Scaffold and fall protection clarification.

Employers should use guardrails, safety nets, or personal fall arrest systems unless they can demonstrate those systems are infeasible or create a greater hazard; only then may an employer implement a fall protection plan with alternative measures.

• There is a regulatory presumption that conventional systems are feasible and not more hazardous; the employer must document a site-specific demonstration to justify alternatives.
• Use Appendix E as guidance, but base the decision on the specific work conditions and a fall protection plan if required.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Fall protection for precast erection.

If an employer implements a fall protection plan under 1926.502(k), it must develop and follow a written plan that identifies the project, describes the alternative measures, and meets the requirements of paragraph (k).

• The plan must be site-specific, prepared by a qualified person, and enforced on the jobsite.
• The employer must first demonstrate that conventional fall protection is infeasible or creates a greater hazard before using the plan for that work.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Fall protection for precast erection.

Employers must provide falling object protection for workers on suspended scaffolds per 29 CFR 1926.451(h), which can include toeboards, debris nets, canopies, or other measures to protect employees below.

• The protection should prevent objects from falling off the scaffold and striking workers below and should be appropriate to the hazards and work being performed.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Scaffold and fall protection clarification.

Employers must secure the base of ladders used on slippery surfaces and ensure top rails are equally supported to reduce fall risks; additional fall protection like harnesses and lifelines may also be appropriate for the task.

• Specifically, 29 CFR 1926.1053(b)(7) requires the ladder base be secured on slippery concrete, and 1926.1053(b)(10) addresses proper support of top rails.
• When workers perform initial connecting work from ladders, employers should consider tying off with body harnesses to lifelines attached to secure anchors.

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation on ladders, Ladder and fall protection requirements.

Body belts are not acceptable as the primary fall arrest device; however, body belts used to restrain a worker on a ladder in a work-positioning application may be part of an employer's interim measures if they meet applicable ladder and fall protection rules and recognized safety guidance.

• OSHA has moved away from body belts for fall arrest and generally requires full-body harnesses when a personal fall arrest system is used.
• For ladder work, securing the ladder and using work-positioning systems with appropriate harnesses and anchorages is the safer, preferred approach.

See 29 CFR 1926 Subpart M and the ladder LOI, Ladder and fall protection requirements.

The employer is responsible for demonstrating, with site-specific evidence, that conventional fall protection is infeasible or would create a greater hazard before using alternative measures or a fall protection plan.

• The employer must document the demonstration and prepare a fall protection plan meeting 1926.502(k) if conventional systems cannot be used.

See 29 CFR 1926 Subpart M and the OSHA letter on precast erection, Fall protection for precast erection.

Employers should review the suspended scaffold fall protection requirements in 29 CFR 1926.451(g) and the falling object protections in 29 CFR 1926.451(h) when temporary conveyances meet the suspended scaffold definition.

• These scaffold provisions address required fall protection, ties, guardrails, and protection for workers below.

See 29 CFR 1926 Subpart M and the OSHA interpretation, Scaffold and fall protection clarification.

No — Appendix E contains sample reasons that may support infeasibility or greater hazard, but employers must make a site-specific demonstration; Appendix E alone is not a blanket justification.

• Employers should document why conventional protection is infeasible or more hazardous for that particular operation and then implement a compliant fall protection plan under 1926.502(k).

See 29 CFR 1926 Subpart M and the OSHA letter of interpretation, Fall protection for precast erection.

If a skylight's capacity is unclear or suspect, the employer must either obtain verifiable capacity information, use a compliant cover that meets 1926.502(i), install guardrails, or provide personal fall arrest systems to protect workers.

• Employers should not assume a manufacturer's claim without verification and should err on the side of protection until they can confirm the skylight meets the required cover criteria.

See 29 CFR 1926 Subpart M and the skylight LOI, Skylight fall protection criteria.

No — falling object protection for suspended scaffolds can include toeboards, debris nets, canopies, barricades, or other effective means appropriate to the hazard and work being performed.

• Employers must select protection that prevents materials or tools from falling and injuring employees below.

See 29 CFR 1926 Subpart M and the scaffold/fall protection LOI, Scaffold and fall protection clarification.