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 6, 2024

Brian Desrosiers
Piedmont Service Group
1031 Nowell Road
Raliegh, NC 27607

Dear Mr. Desrosiers:

Thank you for your inquiry to the Occupational Safety and Health Administration (OSHA) regarding fall protection on low slope roofs. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence and follow-up phone conversations. Your paraphrased scenario, questions, and OSHA's response are below:

An HVAC technician uses a portable ladder to access a low slope roof 12 feet high. The ladder is secured to the building and is placed at a 4/1 angle. The side rails of the ladder extend three feet above the roof landing. The HVAC unit to be worked on is 25 feet from the edge of the roof.

Question: When the employee steps onto the roof's landing from the portable ladder, and while the employee is walking to the HVAC unit, is the employee required to have fall protection?

Response: No. OSHA does not have specific standards that require fall protection when an employee steps off a portable ladder on to a low slope roof and walks directly from the ladder to the work area 25 feet from the edge of the roof. However, when the employee performs work 15 feet or more from the roof's edge, the employer, depending on whether the work is both infrequent and temporary, may be required to provide fall protection in accordance with 29 CFR 1910.28(b)(13)(iii)1.

Question: Does the employee need to have guardrails on the landing surface of the low slope roof once the employee steps off the ladder on to the roof?

Response: No. OSHA does not have specific standards that require guardrails on the landing surface on each side of the portable ladder when an employee steps on to a low slope roof. However, in accordance with 29 CFR 1910.28(b)(13)(i) "[w]hen work is performed less than 6 feet (1.6 m) from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system."

Please note that North Carolina administers its own OSHA-approved state plan, which is required by law to have a program of standards and enforcement that is at least as effective as the Federal OSHA requirements. However, it may enact more stringent requirements. Employers in a state with an OSHA-approved state plan must follow that state's more stringent requirements. For specific information on North Carolina's interpretation and enforcement policy with regard to this issue, please contact:

North Carolina Department of Labor
Occupational Safety and Health Division
1101 Mail Service Center
Raleigh, North Carolina 27699
(919) 707-7806
ask.osh@labor.nc.gov

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to 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 http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Scott C. Ketcham, Acting Director
Directorate of Enforcement Programs

1 See https://www.osha.gov/laws-regs/standardinterpretations/2020-06-12