- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
June 13, 1994
| MEMORANDUM FOR: | OFFICE OF FIELD PROGRAMS REGIONAL ADMINISTRATORS |
| FROM: | JAMES W. STANLEY DEPUTY ASSISTANT SECRETARY |
| SUBJECT: | Fall Protection for Steep Roofs and During the Performance of Built-Up Roofing Work |
Until new subpart M--Fall protection is published, the interim policy regarding fall protection during roofing operations is as follows:
Citations for failure to use fall protection shall be issued to employers engaged in steep roof or built-up roofing activities only when those employers are not in compliance with the requirements of 29 CFR 1926.451(u)(3) for work on steep roofs, and 29 CFR 1926.500(g) for work during built-up roofing operations. Section 5(a)(1) of the Act and 29 CFR 1926.95(a) shall not be used to require fall protection during those operations when the fall distance is less than 16 feet.