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U.S. Department of Labor | ![]() |
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Occupational Safety & Health Administration |
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Standard Interpretations
07/07/2003 - Requirements for fall protection when ladder jack scaffolds are used for residential and commercial construction. |
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Standard Number: | 1926.451; 1926.451(g)(1); 1926.451(g)(1)(i); 1926.452; 1926.452(k)(1); 1926.500; 1926.500(a)(2)(i); 1926.501; 1926.501(b); 1926.501(b)(12); 1926.501(b)(13); 1926.501(b)(2); 1926.502; 1926.502(k); 1926.760 |
July 7, 2003 Tim Blackburn Project Coordinator Brandon Construction Company 557 Alternate 19 North Palm Harbor, FL 34683-4432 Re: Ladder jack scaffolds, fall protection, residential construction; §§1926.451(g), 1926.452(k), and 1926.500(a)(2)(i); STD 3-0.1A Dear Mr. Blackburn: This is in response to your January 13, 2003, letter to the Occupational Safety and Health Administration (OSHA) regarding OSHA requirements for fall protection when ladder jack scaffolds are used. You ask about the applicable standards and alternatives available for residential construction work and commercial work. We apologize for the delay in providing this response. We have paraphrased your questions as follows: Question (1): At what height is fall protection required for employees working on ladder jack scaffolds? For workers on ladder jack scaffolds, are alternatives to the conventional fall protection allowed in residential construction work and commercial work? Answer Where applicable, 29 CFR Part 1926 Subpart M (§§1926.500-1926.503) requires fall protection in residential construction beginning at 6 feet: §1926.501 Duty to have fall protection.However, under §1926.500(a)(2)(i), the fall protection requirements of the scaffold standard (Part 1926 Subpart L), rather than those of Subpart M, apply to workers on scaffolds: §1926.500 Scope, application, and definitions applicable to this subpart.Section 1926.451(g)(1) requires workers on ladder jack scaffolds to be protected by a personal fall arrest system at heights of over 10 feet: §1926.451 General requirements. * * * *OSHA's compliance directive STD 3-0.1A permits the use of certain alternatives to conventional fall protection for some specific work activities in residential construction (discussed in Question (3) below). However, that compliance directive addresses the fall protection requirements in Subpart M, not Subpart L. Since, under §1926.500(a)(2)(i), it is the fall protection requirements of Subpart L that apply to workers on ladder jack scaffolds, the alternative fall protection methods specified in STD 3-0.1A are not available with respect to workers on ladder jack scaffolds. Question (2): Are there rules against using ladder jack scaffolds over 20 feet? Answer Yes. Section 1926.452(k)(1) states: (k) Ladder jack scaffolds. (1) Platforms shall not exceed a height of 20 feet (6.1 m).Therefore, workers are prohibited from being on a ladder jack platform over 20 feet high. This limitation applies in both residential and non-residential construction. Question (3): For workers who are NOT on scaffolds, are alternative fall protection methods allowed to be used in residential and commercial construction? Is there a height limit for use of such methods? Answer Residential construction Under STD 3-0.1A, specific alternatives to conventional fall protection for some activities are allowed to be used in residential construction (copy enclosed). STD 3-0.1A applies only to residential construction. The height limit for application of STD 3-0.1A is 48 feet. If the residential work that you are doing is not within the scope of STD 3-0.1A, in some circumstances you may be able to use alternative fall protection measures where you can demonstrate that conventional fall protection is infeasible. Section 1926.501(b)(13) states: (b) * * *So, if you can demonstrate that conventional fall protection is infeasible, you may implement alternative procedures in a fall protection plan that complies with the requirements of §1926.502(k). Non-residential construction As noted in §1926.502(k), the fall protection plan alternative is only available to employees: . . .engaged in leading edge work, precast concrete erection work, or residential construction work (See §1926.501(b)(2), (b)(12), and (b)(13)) . . .So, in non-residential work covered by Subpart M,1 use of alternative fall protection through a fall protection plan is allowed only in leading edge work and precast concrete erection work. Note that §1926.500 defines leading edge activity in terms of a structural surface that forms an edge that advances/changes as additional sections are installed: The edge of a floor, roof or formwork for a floor or other walking/working surface (such as the deck) which changes location as additional floor, roof, decking or formwork sections are place, formed or constructed. A leading edge is considered to be an 'unprotected side and edge' during periods when it is not actively and continuously under construction.If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. Sincerely, Russell B. Swanson, Director Directorate of Construction 1The fall protection requirements for steel erection are in §1926.760.. [back to text] |
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