OSHA Instruction STD 3-11.1

March 8, 1982 Office of Compliance Programming

Subject: Safety Monitoring System As It Applies to 29 CFR 1926.500(g)(1)

A. Purpose. This instruction clarifies the use of a safety monitoring system to comply with 29 CFR 1926.500(g)(1).

B. Scope. This instruction applies OSHA-wide.

C. Cancellation. This directive cancels OSHA Instruction STD 3.2, dated December 1, 1981. The cancelled directive was erroneously classified, and this directive contains the same information under the proper classification.

D. Action. OSHA Regional Administrators/Area Directors shall take action to ensure that 29 CFR 1926.500(g)(1) is enforced in accordance with F. of this instruction.

E. Federal Program Change. This instruction describes a Federal program change which affects State Programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

2. Explain the technical content of the change to the State designee as reguested.

3. Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing, within 30 days of notification, to the Regional Administrator. This acknowledgment should include a description either of the States plan to implement the change or of the reasons why the change should not apply to that State.

4. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in actual performance.

OSHA Instruction STD 3-11.1

March 8, 1982 Office of Compliance Programming

F. Guidelines.

1. Complying with 29 CFR 1926.500(g)(1) requires the employer to designate a competent person as a monitor as defined in 29 CFR 1926.502(p)(7), capable of identifying and correcting roofing hazards.

2. The individual designated to be monitor may be a supervisor or a worker engaged in the performance of built-up roofing work. The monitor must be trained and capable of identifying existing and predictable roofing conditions which are hazardous, or dangerous to roofing employees.

3. The monitor must have authorization to take prompt corrective measures to eliminate the hazardous conditions. The monitor must be on the same roof as and be able to visibly observe all other employees for whom he/she is responsible and must also be close enough to verbally communicate with the employees.

G. Background. The standard for perimeter guarding of low-pitched roofs allows the use of a "safety monitoring system" under certain conditions. A question has arisen as to what extent a safety monitor might be engaged in the performance of other duties. The preamble to the new standard specifically allows monitors to have other duties but provides that these duties may not be so extensive that they encumber the monitor's duties as a monitor.

Thorne G. Auchter Assistant Secretary

Distribution National Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors