The Occupational Safety and Health Administration's (OSHA's) fall-protection regulations have evolved for decades. Following is a timeline spanning OSHA's history regarding fall protection in the roofing industry.
1971: OSHA developed the first Subpart M, "Floor and Wall Openings," and interpreted it as applying to low-slope roof perimeters.
1975: The U.S. Court of Appeals for the Fifth Circuit determined a floor is not a roof and the requirement for standard railings can't be applied to roofs.
1975-80: NRCA, the roofers union and OSHA worked to develop a roof-specific standard.
November 1980: OSHA published a final rule, "Guarding of Low-Pitched-Roof Perimeters During the Performance of Built-Up Roofing Work," which introduced a warning-line system and safety-monitoring system.
Nov. 25, 1986: OSHA issued a notice it was going to update its standards affecting fall-protection in the construction industry.
1994: OSHA issued its new Subpart M—Fall Protection Standard; the standard included a dramatic change in the height at which the standard's requirements were triggered—from 16 feet to 6 feet. In addition, residential fall-protection options were restricted to "conventional" fall-protection systems—guardrails with toeboards, safety nets and personal fall-arrest systems with snap hooks at each end.
December 1995: OSHA published a directive, Interim Fall Protection Compliance Guidelines for Residential Construction, that allowed other fall-protection systems, such as slide guards, for certain residential roofing work.
July 1999: OSHA issued Advanced Notice of Proposed Rule Making and requested public comments on 10 issues related to fall protection, including a number of topics affecting residential roofing work—slide guards, use of a safety monitor and the definition of "residential construction."
December 2010: OSHA issued a new directive effectively eliminating slide guard use for residential construction.
June 16, 2011: Full implementation of OSHA's residential fall-protection directive originally was scheduled to take place on this day but has been postponed four times; temporary enforcement measures for the fall-protection directive most recently have been extended to March 15, 2013.
This Web exclusive information is a supplement to Falling for safety.
