- 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.
July 1, 1999
MEMORANDUM FOR: EDWARD KASSAK
DAVE HERSTEDT
REGION VIII-FSO
FROM: RUSSELL B. SWANSON, DIRECTOR
DIRECTORATE OF CONSTRUCTION
SUBJECT: James Naylor letter of April 20, 1998
In your letter, dated December 7, 1998, you asked that we respond to two questions regarding the fall protection requirements for working on top of formwork in residential construction.
In residential construction, when employees are standing on top of concrete formwork with a fall hazard in excess of six feet, is conventional fall protection required?
In residential construction, under STD 3.1 [superseded by James Naylor letter of April 20, 1998
In your letter, dated December 7, 1998, you asked that we respond to two questions regarding the fall protection requirements for working on top of formwork in residential construction.
In residential construction, when employees are standing on top of concrete formwork with a fall hazard in excess of six feet, is conventional fall protection required?
In residential construction, under STD 3.1 [superseded by STD 3-0.1A], conventional fall protection is not required for workers working from the top of foundation wall formwork. The letter to Mr. Naylor did not address residential construction and did not address working from the top of formwork.
When employees are standing on top of concrete formwork, (typically on a 2x4 waler) must the surface the employee is standing on be at least 18 inches wide in accordance with Subpart L? If so, are standard guardrails required if the fall distance is greater than 10 feet?
Under STD 3.1, the scaffold requirements do not apply to the top of concrete formwork while the employee is constructing the wall. The Naylor interpretation letter, dated April 20, 1998, dealt with a 2x4 waler attached to the face and about half way up the formwork.
Should you have further questions, please don?t hesitate to write to: Directorate of Construction- Office of Construction Standards and Compliance Assistance,