Sample fall protection plan

An employer must develop a fall protection plan when conventional fall protection is infeasible or would create a greater hazard for leading edge work, precast concrete erection, or residential construction work. See 1926.502(k) and the Sample Fall Protection Plan guidance in Appendix E to Subpart M which explains that a site-specific written plan is required in those situations.

• The plan must be developed on a site-by-site basis and tailored to the actual hazards and sequence of work.
• Appendix E lists common scenarios (leading edge, point of erection, unprotected sides/edges, grouting) where a plan may be needed.
• The plan should document why conventional systems are infeasible or more hazardous and describe alternative measures to protect workers (e.g., safety monitoring, control zones). See 1926.502(k).

The fall protection plan should be prepared by a knowledgeable person, approved by a qualified person, and supervised on site by a competent person designated by the employer. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• The sample form includes fields for "Plan Prepared By," "Plan Approved By," and "Plan Supervised By."
• The plan text assigns implementation responsibility to a named competent person who will perform ongoing observational safety checks and enforce the plan.
• Changes to the plan must be approved by a Qualified Person (as specified in the sample plan).

A written fall protection plan must identify the work areas and activities where conventional fall protection cannot be used, describe the alternative protection systems and procedures, list who is authorized to work in controlled areas, and describe training, monitoring, and rescue procedures. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

Key items to include:

• Scope and project information (location, preparer, approver, date).
• Specific hazardous activities (e.g., connecting activity/point of erection, leading edge work, unprotected sides/edges, grouting).
• Fall protection systems to be used (safety monitoring, control zones, limited use of ladders with tie-offs, etc.).
• Identification and qualifications of safety monitors and designated erectors.
• Training topics, pre-work conferences, and means of communicating restricted access to controlled areas.
• Procedures for hole protection, equipment rigging, and rescue or emergency response.

A safety monitoring system is a fall protection approach where a competent person continuously recognizes and warns employees of fall hazards, and it may be used only when conventional fall protection is infeasible or creates a greater hazard. See 1926.502(k) and the Sample Fall Protection Plan in Appendix E.

• Appendix E explains that safety monitoring is appropriate for certain leading edge and point-of-erection activities when other systems cannot be used safely.
• The monitor must be a competent person whose only duty is to observe and warn monitored employees.
• The system requires limiting the number of workers exposed and restricting access to controlled access zones to trained personnel only.

The safety monitor must actively observe monitored workers and warn them of fall hazards or unsafe actions, communicate orally with them, and refrain from duties that would encumber monitoring. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

Main duties listed in Appendix E include:

• Warn by voice when a worker is approaching an open edge or acting unsafely.
• Warn of dangerous situations developing out of another worker's sight (e.g., a member getting out of control).
• Make designated erectors aware they are in a dangerous area and alert them if they seem unaware of hazards.
• Be competent to recognize fall hazards and remain on the same walking/working surface within visual and verbal communication range of monitored employees.
• Not take on other responsibilities that would prevent continuous monitoring; if encumbered, stop erection or transfer monitoring to another competent person.

One safety monitor may supervise up to six monitored workers according to the sample Fall Protection Plan in Appendix E. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• The sample plan explicitly states "The maximum number of workers to be monitored by one safety monitor is six (6)."
• Employers should ensure the monitor can adequately observe and communicate with all monitored workers at all times.

The safety monitoring system must not be used when wind or weather conditions make loads swing or walking/working surfaces icy or slippery, or when those conditions would prevent the monitor from recognizing hazards. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• Appendix E specifically prohibits use of safety monitoring when wind causes large-surfaced loads to swing out of radius or when weather creates slippery surfaces.
• If environmental conditions prevent effective monitoring, employers must use other fall protection systems that meet the standards.

Designated erectors and safety monitors must be trained in hazard recognition, avoidance techniques, unsafe condition recognition, use and function of protection systems, correct erection/inspection procedures, and knowledge of the construction sequence or erection plan. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

Required training areas listed in Appendix E include:

• Recognizing fall hazards in the work area (leading edge, point of erection).
• Work practices to avoid fall hazards.
• Recognizing unsafe practices or working conditions (e.g., windy conditions).
• The function, use, and operation of safety monitoring, guardrails, body belts/harnesses, control zones, and other protections.
• Procedures for erecting, maintaining, disassembling, and inspecting the systems used.
• Familiarity with the construction sequence and erection plan for the job.

A controlled access zone must be defined and clearly marked with control lines or equivalent means, extend along the unprotected leading edge, be connected to a guardrail or wall at each side, and be erected not less than 6 feet nor more than 60 feet (or half the length of the member being erected, whichever is less) from the leading edge. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

Specific control line requirements in Appendix E:

• Control lines must run along the entire length of the unprotected or leading edge and be approximately parallel to it.
• Control lines must be connected on each side to a guardrail system or wall.
• When control lines are used, they must be 6 ft to 60 ft (1.8 m to 18 m) from the leading edge, or not more than half the length of the member being erected, whichever is less.

Control lines must be flagged at intervals not exceeding 6 feet, rigged so the lowest point including sag is at least 39 inches and the highest point no more than 45 inches from the walking surface, and have a minimum breaking strength of 200 pounds. See 1926.502 and the Sample Fall Protection Plan in Appendix E.

• Flagging or high-visibility markings: every 6 feet (1.8 m) or less.
• Rigging height: lowest point ≥ 39 inches (1.0 m), highest point ≤ 45 inches (1.3 m) from the walking/working surface.
• Minimum breaking strength: 200 pounds (0.88 kN).

(These are the specifications provided in Appendix E for control line systems.)

All openings larger than 12 in. × 12 in. must have perimeter guarding or covers, and predetermined holes should be covered with plywood or equivalent covers shipped with the precast member; covers are not to be removed without the erection foreman's approval except as part of the erection sequence. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• Pre-made plywood covers (provided with the precast member) are to be used for predetermined holes.
• Before cutting new holes on site, employers must provide appropriate protection for the hole.
• Openings may be uncovered only when required for erection at the direction of the erection foreman and only for the minimum time necessary.

The competent person designated in the plan is responsible for implementing, monitoring, and enforcing the fall protection plan, with foremen expected to correct unsafe acts or conditions immediately and employees responsible for following procedures and reporting hazards. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• The plan names a specific competent person who performs continuous observational safety checks and enforces procedures.
• Foremen are explicitly responsible for correcting unsafe acts or conditions without delay.
• Employees must adhere to the plan and report hazards to management if observed.

The safety monitor should be identified by wearing an orange hard hat, and designated erectors should be identified by a blue armband, blue hard hat, or blue vest, per the sample plan. See the Sample Fall Protection Plan in Appendix E.

• Identification helps limit access to controlled access zones to trained personnel only.
• Employers can adopt these or equivalent visual methods to clearly distinguish roles on site.

If the safety monitor becomes too encumbered with other responsibilities, they must stop the erection process and either transfer the other duties to a designated erector or turn over the safety monitoring function to another competent person. See the Sample Fall Protection Plan in Appendix E.

• Appendix E lists three options: (1) stop the erection process; (2) turn over other responsibilities to a designated erector; or (3) transfer monitoring to another qualified, competent person.
• Continuous, unimpaired observation is a key requirement for a valid safety monitoring system.

No — the safety monitoring system can only be used when conventional fall protection (guardrails, safety nets, or personal fall arrest systems) is infeasible or creates a greater hazard; it is not a blanket substitute for conventional systems where they can be used safely. See 1926.502(k) and the Sample Fall Protection Plan in Appendix E.

• Appendix E emphasizes limiting exposures to the minimum number of employees for the minimum time necessary when using safety monitoring.
• Employers must document why conventional methods are infeasible or more hazardous before relying on a plan that uses monitoring or control zones.

The pre-work conference is intended to review erection procedures, sequences, and safety practices with the erection crew, crane crew, and supervisors from other contractors, and it must be conducted by the erection supervisor before the work begins. See the Sample Fall Protection Plan in Appendix E.

• The conference covers the erection sequence, safety practices, and site-specific restrictions (such as controlled access zones).
• All personnel are informed that controlled access zones are off-limits to anyone except trained designated erectors.
• The meeting helps coordinate multiple crews and clarify who is responsible for safety-critical tasks.

For columns 10 ft to 36 ft long, employees disconnecting crane hooks should work from a ladder and wear a body belt/harness tied off with a vertical lifeline attached to the lifting eye; for columns 36 ft and taller the plan prescribes reducing the disconnect height by using an added cable so a ladder can be used safely. See the Sample Fall Protection Plan in Appendix E.

• A vertical lifeline attached to the lifting eye and a manually operated or mobile rope grab are used for tying off.
• Columns must be adequately connected or braced to support a ladder and employee weight.
• In some cases an erection tube or shackle released from the ground may be used to unhook columns, removing the need for elevated disconnect work.

Employees erecting inverted tee beams at heights of 6 to 40 ft are to erect the beam, make initial connections, and perform final alignment from a ladder as described in the sample plan. See the Sample Fall Protection Plan in Appendix E.

• The plan specifies using ladders as the work platform for these specific tasks and includes requirements elsewhere for tying off when both hands are needed.
• Employers must ensure that the methods used (ladders, tie-offs, bracing) are safe and documented in the site-specific plan.

Yes — Appendix E recommends that erectors discuss the written fall protection plan with their OSHA Area Office prior to going on a jobsite as a best practice. See the Sample Fall Protection Plan in Appendix E.

• This is presented in Appendix E as a recommendation to help ensure the plan is site-specific and consistent with OSHA expectations.
• Consultation with the Area Office can provide helpful feedback but does not substitute for the employer’s responsibility to comply with 1926.502(k).

Control lines must be rigged so the lowest point, including sag, is not less than 39 inches from the walking/working surface and the highest point is not more than 45 inches from the walking/working surface. See the Sample Fall Protection Plan in Appendix E and 1926.502.

• The sagging distance must be accounted for when measuring the lowest point.
• These heights are specified in Appendix E to ensure control lines are visible and effective at keeping workers away from edges.

Only individuals with the appropriate experience, skills, and training who have been specifically authorized and trained may be designated as "designated erectors" to enter controlled access zones without conventional fall protection. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• The sample plan requires listing the names of designated erectors and confirms they must receive the training topics specified in Appendix E.
• Identification (blue armband/hat/vest) should be used so others know who is authorized to work in the controlled access zone.

Before cutting holes on the jobsite, proper protection for the hole must be provided; predetermined holes should have plywood covers made in the precasters' yard and shipped with the member, and perimeter guarding or covers must not be removed without the erection foreman's approval. See the Sample Fall Protection Plan in Appendix E.

• All openings greater than 12 in. × 12 in. must have perimeter guarding or coverings.
• The opening used for erecting a column becomes part of the point of erection and is addressed in the fall protection plan; uncovering is done only immediately prior to use and only at the foreman's direction.
• Except for openings in active use for erection, covers and guarding must remain in place.

Any changes to the fall protection plan must be approved by the named Qualified Person identified in the plan before being implemented. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• The plan requires a designated Qualified Person's approval for changes to ensure modifications are safe and site-appropriate.
• Employers should document approvals and revisions to maintain a clear record of the current plan.

Employers must expose only the minimum number of employees necessary and only for the time required to accomplish the task when using non-conventional protection like safety monitoring or control zones. See the Sample Fall Protection Plan in Appendix E and 1926.502(k).

• Appendix E explicitly states the plan will "expose only a minimum number of employees for the time necessary to actually accomplish the job."
• Controlled access zones and identification of designated erectors help limit who is exposed.
• Employers should plan sequences to minimize exposure time at unprotected edges.

Yes — under OSHA's definitions, conveyances that operate with temporary guides, temporary suspension means, or temporary hoists can meet the definition of a suspended scaffold and thus are subject to scaffold fall protection requirements; see the OSHA interpretation clarifying this application. See 1926 and the OSHA letter of interpretation "Scaffold and fall protection clarification" (https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05).

• The 2023 LOI explains that many conveyance configurations would meet the definition of a suspended scaffold under 29 CFR 1926.450(b) and therefore must comply with scaffold fall protection rules in [29 CFR 1926.451(g) and (h)].
• Employers should ensure that fall protection for temporary conveyances meets both scaffold requirements and any site-specific fall protection plan elements.

Using a ladder to disconnect a crane from a beam is acceptable only when the beam is placed at a height where ladder use is practical (the plan says ladders are not practical above 40 ft). For high placements, the plan requires initial placement with tag lines and final alignment from a manlift or similar system rather than ladders.

• The sample plan states ladders will be used to disconnect the crane from beams at accessible heights and that "the use of ladders is not practical at heights above 40 ft," so manlifts or employee positioning systems are used there. See the sample fall protection plan in 1926 Subpart M App E.
• Also consider the fall protection requirements in 1926.502 when planning ladder disconnects (for example, requirements for proper anchorage or other fall-protection methods).

A safety monitoring system can be used for designated erectors working at the leading edge when a properly constructed control zone is established and a competent safety monitor continuously monitors the workers; the plan specifically uses safety monitoring plus control zone lines for leading-edge precast erection.

• The plan requires control zone lines not more than 60 ft from the leading edge supplemented by a safety monitoring system to protect designated erectors; see 1926.502(k) and the sample plan in 1926 Subpart M App E.
• Ensure the safety monitor meets the criteria in 1926.502(k) (able to recognize fall hazards and warn workers) and that the control zone dimensions in the plan are implemented and enforced.

Control zone lines can be up to 60 feet from the leading edge for the precast erection procedures described in the plan, with safety monitoring used to protect workers inside that zone.

• The sample plan specifies "control zone lines not more than 60 ft away from the leading edge" and supplements them with a safety monitoring system; see 1926 Subpart M App E and the safety-monitoring rule in 1926.502(k).
• Make sure the control zone is clearly marked and all designated erectors are aware of the boundaries and the role of the safety monitor.

When perimeter protection is removed bay-by-bay for cladding installation, workers receiving and positioning cladding within 6 feet of the unprotected edge must be tied off.

• The plan states that when perimeter protection is removed temporarily, "Those workers within 6 ft of the edge, receiving and positioning the cladding ... shall be tied off." See 1926 Subpart M App E and the fall protection requirements in 1926.502.
• For workers performing tasks more than 6 ft from an unprotected edge, a warning line or control lines must still be used to indicate approaching fall-hazard areas per the plan and applicable rules.

The plan says PFAS are not used because attaching workers to lifelines during the complex, short-duration maneuvers at the leading edge would create additional hazards (entanglement, restricted movement, and increased risk of being trapped by moving loads) that could increase the overall fall risk.

• The plan explains that lifelines/lanyards can restrict movement, cause entanglements between workers, prevent necessary quick movement to avoid moving structural members, and interfere with the task of positioning heavy precast sections; see 1926 Subpart M App E and fall protection criteria in 1926.502.
• Where PFAS would increase risk, the plan relies on engineered procedures like tag lines, control zones, safety monitoring, and specialized rigging instead of mandatory PFAS for those specific erection steps.

Retractable lifelines are generally not appropriate in this precast erection sequence because they can tangle, clog with grout or debris, produce slack that damages the retraction mechanism, and prevent quick escape from moving loads.

• The plan specifically warns that retractable devices can become entangled or clogged (for example, with grout), may lock at speeds that prevent quick movement, and can create other hazards that outweigh their fall-prevention benefits; see 1926 Subpart M App E and fall protection requirements in 1926.502.
• When retractable lifelines would introduce these hazards, the plan assigns control measures such as safety monitoring, control zones, and special rigging procedures instead.

Designated erectors should approach an incoming hollow-core slab at the leading edge only after the slab is below waist height whenever possible, so the member itself offers some fall protection during positioning.

• The plan states that workers will approach the incoming member only after it is below waist height when possible and that hollow-core slabs on masonry will be erected and grouted using the safety monitoring system; see 1926 Subpart M App E and 1926.502(k).
• The safety monitor must continuously observe and be able to warn workers of fall hazards while work is performed within the control zone.

A designated erector waiting for the next floor or roof member must stay at least six (6) feet from the unprotected edge while under the control of the safety monitor.

• The sample plan directs designated erectors to remain a minimum of six (6) ft from the edge while they wait and requires that movements along the member preserve that 6-ft minimum distance at all times; see 1926 Subpart M App E and fall protection rules in 1926.502.
• The safety monitor must supervise any movement within the control zone per 1926.502(k).

For loadbearing wall panels, the plan requires a controlled access zone that is at least 25 feet from the unprotected edge and at most one-half the length of the wall panels away from the edge so erectors can move freely when receiving panels.

• The plan states "the erection of the loadbearing wall panels ... requires the use of a safety monitor and a controlled access zone that is a minimum of 25 ft and a maximum of ½ the length of the wall panels away from the unprotected edge"; see 1926 Subpart M App E and the safety-monitoring requirement in 1926.502(k).
• Bracing that must be installed by ladder should be done before disconnecting the crane, and workers must be protected while cranes are disconnected.

Designated erectors are allowed onto the suspended double tee during the two-lining procedure without tying off while the members are stabilized and the safety monitoring system is in use, because tying off would create entanglement and crushing hazards during the maneuver.

• The plan explains that during the two-lining process erectors "will not tie off during any part of this process" and that the safety monitoring system will be used while they are on the double tee; see 1926 Subpart M App E and the safety-monitoring provision in 1926.502(k).
• Keep in mind that a safety monitor must be competent as required by 1926.502(k), and that the plan specifies additional rigging, communication, and staging controls to reduce hazards during this operation.

Yes — anchorages or special attachment points can be cast into precast members, but only if they are preplanned and approved by the engineer who designed the member.

• The plan states "Anchorages or special attachment points could be cast into the precast concrete members if sufficient preplanning and consideration of erectors' position is done before the members are cast" and that any hole or other attachment must be approved by the engineer; see 1926 Subpart M App E and the anchorage and system requirements in 1926.502.
• Follow the design engineer's approval and applicable anchorage strength and certification criteria before relying on such cast-in attachments for fall protection.

The plan requires avoiding tying workers to lifelines in certain operations because a tied worker can be trapped or crushed by moving members; instead it relies on procedures such as tag lines, safety monitoring, control zones, specialized rigging (two-lining), and ensuring quick egress paths.

• The plan explains that tying workers to lifelines may trap them if a moving structural member restrains them and that sudden movement of precast members can occur for many reasons (crane error, wind, rigging failure, etc.), so alternative controls are used; see 1926 Subpart M App E and fall-protection provisions in 1926.502.
• When tying-off would create greater risk, use the hierarchy of controls: engineering/rigging controls, administrative procedures (safety monitor, communication), and exclusion/control zones rather than PFAS that could entangle or restrain workers.

Yes — employees exposed to falls of 6 feet or more who are less than 6 feet from an unprotected edge and are not performing leading-edge erection or connecting activities must be tied off at all times or be protected by guardrails.

• The plan states that employees exposed to falls of six (6) feet or more who are not engaged in leading-edge erection or connecting must be tied off if working less than six (6) ft from an unprotected edge or have guardrails installed; see 1926 Subpart M App E and the general fall-protection rules in 1926.502.
• If these employees are more than six (6) ft from the unprotected edge, a warning line or control lines must still be erected to remind workers they are approaching an area where fall protection is required.

The plan manages changing perimeters by establishing control zones, using safety monitoring, staging erection so the work deck area increases progressively, and requiring erectors to follow specific approaches (e.g., approach incoming members when below waist height) so fall protection is assured as the leading edge moves.

• The plan acknowledges that the unprotected floor/roof perimeter is constantly modified and prescribes control zone lines supplemented by a safety monitoring system to protect designated erectors; see 1926 Subpart M App E and the safety-monitoring rule in 1926.502(k).
• Practical steps in the plan include approaching incoming members below waist height when possible, using tag lines, and ensuring workers follow the safety monitor's directions to stay clear of unprotected edges.

If a conveyance or temporary platform meets the definition of a suspended scaffold, fall protection and falling-object protection must meet the suspended scaffold requirements in 29 CFR 1926 Subpart L (including 1926.451(g) for fall protection) and applicable fall-protection criteria in [1926.502].

• OSHA's interpretation clarifies that conveyances operating with temporary guides, suspension cables, or temporary hoists can meet the definition of a suspended scaffold and thus fall under scaffold fall-protection rules; see the LOI at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05 and the applicable fall-protection requirements in 1926.502.
• Ensure the platform's anchorage, guardrails, personal fall arrest systems (when required), and falling-object protections comply with the scaffold standard and are implemented per the LOI guidance and 1926.451(g)/(h).

No — tying off to lifting loops on double tees is not a simple compliance solution and comes with specific hazards and remediation needs. Appendix E explains that while lifting loops might look like logical tie-off points, they often must be cut off later to eliminate a tripping hazard and attachments located other than on the deck surface will require removal or patching, which itself exposes employees to additional fall hazards during removal or patching. See the discussion in 1926 Subpart M Appendix E and the anchorage/attachment requirements in 1926.502.

Generally no — installing temporary supports as lifeline anchorages is often not feasible and can increase hazards. Appendix E explains that temporary supports reduce the space needed for safe positioning, are likely to be struck or moved by the shifting precast member (which could pull tied-off workers off the work surface), and take more manhours to install and maintain than the erection task itself, exposing employees erecting those supports to additional fall hazards. Employers must consider these hazards when evaluating anchorage feasibility under 1926.502 and follow the guidance in 1926 Subpart M Appendix E.

No — using a horizontal cable between columns for tie-off is not considered feasible in many erection situations and creates serious additional hazards. Appendix E lists multiple problems: installing the cable requires more fall exposure time than the beam connection task; a waist-level cable next to a connector prevents centering weight and balancing; overhead attachments may not exist at higher levels; attaching below foot level can increase fall distance beyond 6 feet; and cables strung over beams make it easy for lifted members to foul or dislodge the cable, potentially causing a fall. See 1926 Subpart M Appendix E and the fall protection requirements in 1926.502.

No — anchoring retractable lifelines at floor level or to moveable/flexible anchorages is generally unacceptable because it increases free‑fall distance, impact forces, and swing hazards. Appendix E cites ANSI guidance and manufacturer warnings that retractable devices should be positioned above the harness D‑ring and that anchorages should be immovably fixed and independent of the user's support system. Moveable or highly flexible anchorages (including horizontal cables) can amplify arrest forces or allow oscillation that defeats the lifeline's braking function. See the manufacturer/ANSI discussion in 1926 Subpart M Appendix E and the applicable fall arrest rules in 1926.502.

Dragging a retractable lifeline across an edge can cause a dangerous pendulum swing, increased fall distance, and a higher risk of cable failure. Appendix E explains that the lifeline can swing a worker until the line reaches the shortest path to the edge, lowering the worker and increasing the chance of striking the floor or obstructions; simultaneous edge abrasion during peak loading raises the risk of cable breakage. These hazards are discussed in 1926 Subpart M Appendix E and should be considered alongside the requirements in 1926.502.

A competent person may designate certain erectors to work without personal fall arrest systems only after evaluating site‑specific conditions and determining that using PFAS is not feasible or creates greater hazards. Appendix E states the competent person — who understands the specialized operations on the project — should determine when and where a designated erector cannot use a personal fall arrest system. That determination must account for the risks described in Appendix E and the anchorage and fall protection provisions in 1926.502.

Safety nets are often impractical for precast erection because there are frequently no structural attachment points where protection is needed, and the point of erection moves constantly so nets would need repeated installation, testing, and relocation, increasing worker exposure. Appendix E explains that interior high bays often lack rigging points, nets would only protect a single member before needing relocation (and strict reading of 1926.502(c) requires nets to be in place and tested before operations), and repeated net installation would extend exposure time for the installers beyond that of the workers the net is intended to protect. See 1926 Subpart M Appendix E and 1926.502(c).

No — guardrails are generally impractical at changing leading edges during precast placement because they obstruct safe positioning and must be removed to allow members to be swung and placed. Appendix E explains that the perimeter changes each time a member is placed and that obstructions above floor level near the point of erection must be removed so workers can swing and position large members safely; installing and reinstalling guardrails at the ever‑changing leading edge is therefore unreasonable. See the operational discussion in 1926 Subpart M Appendix E and the perimeter protection requirements in 1926.502.

Under 1926.502(c), an employer may not simply leave workers unprotected; if a guardrail would create a greater hazard or make the work unsafe, the employer must document that conventional fall protection is infeasible and implement a site‑specific plan with alternative measures such as a controlled access zone and safe work procedures.

• The employer must develop and follow a written, site‑specific Fall Protection Plan that explains why guardrails (or other conventional systems) are infeasible for that operation and identifies the alternative measures that will be used (1926.502).
• The sample Fall Protection Plan in OSHA's Subpart M Appendix E explains practical alternatives used during precast erection: keep non‑erectors off the deck until grout hardens, restrict work at the leading edge, use controlled access zones, limit work to trained personnel, and rely on stabilized members and specific work sequencing instead of guardrails (1926SubpartMAppE).
• Controls the plan should include: clear demarcation of the work/CAZ, restriction of access to authorized and trained employees, procedures for safe swinging and placement of loads (terminate any rail/handrail that would obstruct placement), bracing/stabilizing members before use, and continuous competent‑person oversight and monitoring.
• If at any point conventional fall protection becomes feasible, the employer must implement it; if a fall or serious incident occurs, the plan must be reviewed and revised as needed (see the plan’s sections on enforcement, accident investigation, and changes to the plan in 1926SubpartMAppE).

Under 1926.502(k), a Controlled Access Zone (CAZ) used in lieu of conventional systems must be established and controlled by a competent person and must limit access and exposure through clearly defined procedures and demarcation.

• The competent person must define the CAZ and ensure it is clearly marked or controlled (for example, by signs, wires, tapes, ropes, or chains) before work begins, per the sample plan (1926.502(k)).
• Access must be restricted to authorized entrants only; the plan should identify who is authorized (listed or otherwise visibly identifiable) and the competent person must verify that only those people enter the CAZ (OSHA Subpart M Appendix E).
• The competent person must ensure all protective elements and safe‑work procedures for the CAZ are implemented before work starts (for example, using interior or sawhorse scaffolds where feasible, stabilizing the first trusses before standing on them, and requiring only trained workers to perform erection tasks).
• Employers must train employees allowed in the CAZ on the CAZ limits, safe procedures, and what to do if they believe the chosen methods create a greater hazard; workers must notify the competent person if they encounter a condition that increases hazard.
• The CAZ and procedures must be continuously monitored and the Fall Protection Plan must be reviewed and revised if a fall or other serious incident occurs (see the plan’s sections on monitoring, accident investigation, and changes to the plan in 1926SubpartMAppE).