Residential Fall Protection STD 03-00-001 – Rescinded

Pole Guy

Hi, it’s the Spanish OSHA Guy here! On June 16, 2011 OSHA rescinded a provisional rule they put into affect in 1995 that spelled out alternative means of fall protection for residential construction. Based on the people in my OSHA 10 hour training, this has been much a joke for most residential construction workers because two key elements were not required. I’ll quote from the original rule which you can read on the OSHA website. This quote comes from the very beginning in the “PURPOSE” section,

…In general, that provision [Fall protection requirements for residential construction, 1926.501(b)(13)] requires conventional fall protection for work at or over six feet. However, OSHA Instruction STD 3.1 [or STD 03-00-001] modifies those requirements. It permits employers engaged in certain residential construction activities to use alternative procedures routinely instead of conventional fall protection. No showing of infeasibility of conventional fall protection is needed before using these procedures. A fall protection plan is required but it does not have to be written nor does it have to be specific to the jobsite. Different alternative procedures are specified for different activities.

The boldface type and underlining was added by me for emphasis.

So now -since this rule was rescinded as of June, 16 2011- what must happen is the opposite of what I have in bold. Now it is necessary to show the infeasibility of conventional fall protection and an alternate fall protection plan must be in writing and be specifically for the jobsite. OSHA has a fantastic webpage on their website that has several valuable links for further detail. This page has a FAQ section, Compliance Guide for employers, PowerPoint for trainers, the Compliance Directive and much more.

By the way, the compliance directives are written for the OSHA inspectors. They give guidance as to what questions, to ask, procedures to follow and how to carry out an OSHA inspection on a specific topic. Any safety trainer, consultant, or safety professional would do very well to read those documents (or at least portions of those documents 🙂 ) because they spell out exactly what OSHA will and will not cite for violations on a given safety topic.

So in summary, here is a quote from the executive summary from OSHA’s new GuidingDocument for Residential Fall Protection,

On December 16, 2010, OSHA issued STD 03-11-002, Compliance Guidance for Residential Construction, which rescinds STD 03-00-001, Interim Fall Protection Compliance Guidelines for Residential Construction, and provides that OSHA will be enforcing 29 CFR 1926.501(b)(13) for all residential construction work.

Click here to reference this on the OSHA website. And finally, you can view my video explaining my unique approach to OSHA 10 and 30 hour training. I hope this was helpful! Until next time. -Steven St. Laurent

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