osha warning line requirements

Price $21.86. By connecting the line from rail to the rail, … The employer effectively implements a work rule prohibiting the employees from going past the warning line. Determine if mechanical equipment will be used for the work. A proximity alarm set to give the operator sufficient warning to prevent encroachment into the minimum approach distance. Three. Furthermore, when these other trades use a warning line system in accordance with the policy described above, the workers must use conventional fall protection when they are outside the protection of the warning line system. 3. Implement at least one of the following measures: a. Section 1926.501 defines a warning line as: Section 1926.502 (fall protections systems criteria and practices) provides: Significantly, the definition and the referenced §1926.501(b)(10) both refer to or relate to roofing work. This use is set forth in §1926.502(k)(7): Again, the option of a Fall Protection Plan is only available where the employer has overcome the presumption that conventional fall protection is feasible.7 The TrafFix Devices Roof Edge Delineator warning line meets or exceeds the requirements in 1926.502 (f) (2). Erect and maintain an elevated warning line, barricade, or line of signs, in view of operator, at the required minimum approach distance (see detailed requirements in OSHA regulation). OSHA’s employee alarm systems standard 29 CFR 1910.165 applies to all employers that use an alarm system to satisfy any OSHA standard that requires employers to provide an early warning for emergency action, or reaction time for employees to safely escape the work place, the immediate work area, or both. 40692, this Section, entitled "Residential construction" requires: The Preamble continues at 59 Fed. Question 3(b): What about for metal roofing? OSHA's fall protection standard for construction, 29 CFR 1926 Subpart M (beginning at §1926.500), generally requires fall protection when there is a fall distance of 6 feet or more. In your letter you state that other trades (for example, electricians and mechanical trades), when working on roofs, tie-off only when they go outside the warning line system. Reg. Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs Specifically, under these circumstances, can we use warning lines instead of conventional fall protection for those workers? which are supported by stanchions that are designed to withstand being tipped by 16 pounds of pressure 30” from the walking or working surface. Section XII of the Directive sets forth alternative fall protection systems for certain defined residential roofing work.5 However, it does not include warning line systems as an alternative. OSHA: A warning line is used 15' or more from the edge. Whenever using any type of accident prevention sign or tag, it is essential to understand all the requirements. [ back to text ], 8 It should be noted that the definition of "Steep roof" and the conventional fall protection delineated in this Section would have equal application to the residential roofing activities referenced in Questions (1) and (2). An OSHA inspection was conducted at Raul's workplace. 10 Section 1926.751 defines "Leading edge" as: Occupational Safety & Health Administration, Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. Our response to your company's question regarding the potential use of "controlled access zones" in conjunction with residential roofing activities parallels our answer to Question (1). Reg.40685 notes: 5 As in the Standard, the Directive sets forth specific residential roofing variables reflecting slope and roof type that affect the availability of the alternative fall protection options. OSHA recognized that guardrail systems, safety net systems and personal fall arrest systems could pose feasibility problems during roofing work; therefore, the rule allows other choices of fall protection methods. Also, from time to time we update our guidance in response to new information. Russell B. Swanson, Director When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to … Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. Reg. In some circumstances, a warning line system may be used as part of a fall protection plan under §1926.502(k) where an employer demonstrates the infeasibility of conventional fall protection.4 However, as noted in §1926.502(k) itself, the fall protection plan alternative is only available to employees: The described work is not precast concrete erection work (see §1926.501(b)(12)). We assume for the purposes of this response that the work to be performed is within the purview of [that] definitions. [ back to text ]. No. b. Employers are expected to adhere to all OSHA requirements (see our checklist above). 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. (C) The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over. Custom Design Services Leading Edge Safety is more than a fall protection company. Does Raul have a right to this information? [Corrected 6/2/2005], Occupational Safety & Health Administration. Managing Principal We have paraphrased your questions below: More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. Acceptable use of warning lines as fall protection for roofers and other trades. The installation of that type of metal roofing is not leading edge work, since it is not structural, and does not form an edge of a walking/working surface. Foremen and superintendents need to ensure a proper warning-line system setup. It provides in part: Section 1926.500 defines "Low-slope roof" as: Thus, the intended residential roofing activities on roofs with a slope greater than 4 in 12 would not meet the stated criteria of these sections that allow for the use of a warning line system.3 As §1926.501(b)(10) is the only provision that specifically provides for the use of a warning line system (in conjunction with another system) as fall protection for roofing activities, the employer here cannot use such a system unless another provision in the Standard or the Directive applies. A stairway has 6 steps. Under paragraph 1926.501(b)(2), 1926.501(b)(12), and 1926.501(b)(13), employers engaged in other specified work, such as leading edge work, precast concrete erection, and residential construction may develop and implement a site specific fall protection plan that uses alternative fall protection methods if they can demonstrate infeasibility of conventional fall protection. The installation of such decking is leading edge work10 and is included in the steel erection standard (Part 1926 Subpart R) as a steel erection activity under §1926.750(b)(1). Let’s back up a moment. Sincerely, Despite this fact, pipe marking doesn’t need to be terribly difficult because you can follow one set of requirements that will help you satisfy all of the others: ANSI/ASME A13.1. 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. As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. Flag warning lines with a highly visible material at 6-foot intervals. Given the regulatory history and the presumptions set forth in the Standard, the potential for use of warning lines in this instance appears to be remote. Section 1926.501(b)(10) allows roofers working on low-sloped roofs to have several fall protection options. Section 1926.500 defines a "Controlled Access Zone" ("CAZ") as: Particular requirements associated with its use are delineated in §1926.502(g). The Directive only applies to employees engaged in residential construction performing specified activities. Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination with monitors in place of personal fall protection equipment or guardrails. OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." Specifically, the referenced §1926.501(b)(10) limits the use of warning lines to low-slope roofs. As we explained in a letter to Mr. Barry Cole last year, we have determined that in the areas further back from the distances specified for the warning lines permitted under the standard, there is a point that is sufficiently far from the edge to warrant the application of a de minimis policy regarding non-conforming guardrails. OSHA's fall protection standard for construction, 29 CFR Part 1926 Subpart M (Fall Protection) ("Standard"), as well as its related Directive Number STD 3-01.A ("Directive")1 generally require[s] conventional fall protection (guardrail systems, personal fall arrest systems, or safety net systems) for work where there is a fall distance of 6 feet or more. Yes. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to … Mark Troxell, Director of Safety In general, OSHA's fall protection standard requires that anyone working at heights of 6 feet or more be provided with fall protection. Warning Line System Requirements. [ back to text ]. Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination … In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. In such a setting, can a roofing contractor use controlled access zones or warning lines when engaged in roofing activity on a roof with a slope greater than 4 feet vertical to 12 feet horizontal? If unapproved signs or tags are used, it not only puts those in the area at increased risk, but can also result in a citation from OSHA if it is discovered upon inspection. Warning-line systems consisting of ropes, wires or chains and supporting stanchions should be set up as follows: The warning line must be erected around all sides of the roofing work area. This is in response to your letter dated February 25, 2003, to the Occupational Safety and Health Administration (OSHA). Note that our enforcement guidance may be affected by changes to OSHA rules. 1926.502 (f) (1) (i) When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge. Question (2): Assuming the same scenario set forth in the first paragraph of Question (1), can controlled access zones be used for residential roofing activities when the roof slope is greater than 4 feet vertical to 12 feet horizontal? The Difference Between OSHA and ANSI. Answer This responds to your July 19, 1999 letter to the Occupational Safety and Health Administration (OSHA) requesting clarification on the use of fall protection for employees, other than roofers, working on low slope roofs. If what you need is fall prevention, then please see our safety railing solutions. If a worker works within 2 metres of the control zone i.e. A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and ; The employer effectively implements a work rule prohibiting the employees from going past the warning line. [ back to text ], 7 The previous discussion on "feasibility" in footnote 3 is equally applicable here. Also, from time to time we update our guidance in response to new information. In some cases warning lines may be used under these provisions. If you need 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. This letter constitutes OSHA's interpretation of the requirements discussed. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. Dear Mr. Troxell: at 40677: As the described roofing activities are not related to overhand brick laying, precast concrete work, or leading edge work6, the only potential in the Standard for use of a controlled access zone again arises in the context of a Fall Protection Plan for residential construction work. 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