![]() ![]() ![]() Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of §1926.502. Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. As explained in our recent letters to Dennis Vance dated December 8, 2003, and Alberto Torres dated June 30, 2003, (copies enclosed) where one component aspect of a structure (such as the roof) is typical of what is used in structures covered by the directive, but the structure when considered as a whole is not, STD 3-0.1A is inapplicable. The fact that the roof trusses are typical of the materials used for roofs in single family and townhouse construction covered by STD 3-0.1A is not, by itself, sufficient to bring the work within the scope of that directive. In your case, based on the submitted photos, the structural frame is predominantly structural steel, not stick-framing. The work site you describe falls beyond the scope of STD 3-0.1A. The methods and procedures set forth in STD 3-0.1A were specifically designed to address the hazards unique to traditional stick frame, single family home construction. Under this directive, an employer is permitted to use alternative fall protection procedures without having to show the infeasibility of conventional fall protection where the methods and materials of the structure as a whole are essentially the same as those used in the construction of stick-built, single-family homes. Such discrete parts of a commercial building would qualify as residential construction where the characteristics listed above are present. In addition, the construction of a discrete part of a large commercial building (not the entire building), such as a wood frame, shingled entranceway to a mall, may fit within the definition of residential construction.Methods: Traditional wood frame construction techniques.Materials: Wood framing (not steel or concrete) wooden floor joists and roof structures.Residential construction is characterized by:. ![]() For purposes of this instruction, an employer is engaged in residential construction where the working environment, materials, methods and procedures are essentially the same as those used in building a typical single-family home or townhouse.STD 03-00-001 does not apply.Ĭompliance directive STD 3-0.1A states: Definition of "residential construction." What fall protection requirements apply to workers engaged in installation of the wooden roof trusses on such buildings? Does STD 3-0.1A apply? Is this considered "residential construction" under §1926.501(b)(13)? Do you agree with our view that the use of personal fall arrest systems for these workers is infeasible or would create a greater hazard? The work in question is the installation of the wooden roof trusses. Question (1): The buildings at the work site are constructed of "red iron" (hot formed structural steel) beams and columns, metal stud curtain walls, wood roof trusses, and a synthetic stucco EIFS (Exterior Insulation Finish System) and brick exterior. We have paraphrased your questions as follows: We apologize for the delay in responding. You ask about fall protection requirements for employees engaged in roofing activities on your construction site. This is in response to your letter faxed on September 25, 2003, to the Occupational Safety and Health Administration (OSHA). ![]()
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