leading edge. We are concerned about the fall protection required for workers engaged in residential "roofing work," as that term is described in the Directive, on a roof with a slope greater than 4 feet vertical to 12 feet horizontal. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. Warning lines only serve to warn someone of a fall hazard, they do not provide any actual resistance to a fall. 3 CAZ Controlled access zones [See § 1926.501(b)(9) and § 1926.502(k)] and their use shall conform to the following provisions. falling from heights, or to warn a person to avoid approaching a fall hazard (i.e., warning systems, warning lines, audible alarms, signs or training of workers to recognize specific fall hazards). In some circumstances, a warning line system may be used as part of a fall protection plan under §1926.502(k) where an employer demonstrates the infeasibility of conventional fall protection.4 However, as noted in §1926.502(k) itself, the fall protection plan alternative is only available to employees: The described work is not precast concrete erection work (see §1926.501(b)(12)). The purpose of the warning line is not to prevent access to the control zone but to provide a visual and physical reminder of the presence of the hazard. 4 The Preamble at 59 Fed. Section 1926.500 defines a steep roof as follows: Section 1926.501(11) delineates the fall protection required for employees working on such roofs as follows: The Standard does not permit the use of controlled access zones, warning lines, or other alternative fall protection methods for nonresidential roofing activities on steep roofs. Reg. • Use and operation of the controlled access zone, guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems; • The role of each employee when a safety monitoring system is used; • Specific criteria for the use of mechanical equipment performing roofing work on Under both the Controlled Access Zone and Warning Line System strategies, a warning line and the unprotected side or edge, 2. Reg.40685 notes: 5 As in the Standard, the Directive sets forth specific residential roofing variables reflecting slope and roof type that affect the availability of the alternative fall protection options. Warning line systems are installed around all edges of a roof, whereas a controlled access zone is limited to one specific area of a job site The rope, chain or wire used in the warning line system must have a minimum tensile strength of 500 pounds, as opposed … As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. Reg. and other operations are taking place defined by a control line or by another means that restricts access? [This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy.] Controlled access zones are designed to provide added safety for workers in elevated areas of the worksite. Each line shall be rigged and supported in such a way that its lowest point (including sag) is not less … erecting precast concrete panels or overhand bricklaying). Warning line systems 7 Safety monitoring systems 7 Controlled access zone 7 Covers 7 IV. at 40677: As the described roofing activities are not related to overhand brick laying, precast concrete work, or leading edge work6, the only potential in the Standard for use of a controlled access zone again arises in the context of a Fall Protection Plan for residential construction work. Dayton, OH 45420-0246 This use is set forth in §1926.502(k)(7): Again, the option of a Fall Protection Plan is only available where the employer has overcome the presumption that conventional fall protection is feasible.7 [29 CFR 1926.502(g)(1)] Y N N/A When control lines are used, are they erected at least 6 but not more than 25 feet from the unprotected or . Designed to designated areas and to alert workers of dangerous conditions, this system can help prevent accidents. 29 CFR 1926.502(g)(2)(i). The differences between a warning line and a controlled access line are that a warning line must strong enough so that if a worker backed up to it , the y would be stopped by the line, wh ile a caution line is used to keep other workers out of an area. Come join the discussion about the industry, safety, finishing, tools, machinery, projects, styles, scales, reviews, accessories, classifieds, and more! Nor does it include nonresidential roofing work as an activity for which a §1926.502(k) fall protection plan may be used as an alternative to conventional fall protection. Also, from time to time we update our guidance in response to new information. General requirements for lines and stanchions are similar to warning lines, except that the minimum breaking strength for lines is only 200 pounds. The warning line designates an area in which roofing work may take place without the use of guardrail, body harness, or safety net systems to protect employees in the area if a safety monitoring system is used. [ back to text ], 6 See earlier discussion on leading edge work. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. Reg. *No. Using a fall-protection plan 8 Fall protection requirements 8 Guidelines for developing a fall-protection plan 9 VII. A warning line system is a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge. Signs shall be posted to warn unauthorized employees to stay out of the controlled access zone. Title: CAZ Controlled Access Zones 1 CAZ(Controlled Access Zones) 2 CAZ. The Directive only applies to employees engaged in residential construction performing specified activities. The PermaLine warning Line was designed for permanent placement of a roof warning line system for roof edge fall protection. The installation of that type of metal roofing is not leading edge work, since it is not structural, and does not form an edge of a walking/working surface. If the control line is attached to a guardrail system, this system must comply with the requirements in §1926.502(b). 3100 Research Blvd. Controlled Access Zones - 1926.502(g) A controlled access zone is a work area designated and clearly marked in which certain types of work (such as over-hand bricklaying) may take place without the use of conven-tional fall protection systems—guardrail, personal arrest or safety net—to protect the employees working in the zone. Points of access, materials handling areas, storage areas, and hoisting areas shall be connected to the work area by an access path formed by two warning lines. However, where the employer can demonstrate that conventional fall protection is infeasible and that a warning line is the most protective alternative means of fall protection, it may be used as part of a residential construction Fall Protection Plan. (See the Fall Protection-Part 3 checklist for requirements.) Do you require your guys to be tied off when inside of an access path dumping trash off of the edge?.. LJB, Inc. Dear Mr. Wright: Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. In that case, the fall protection requirements in §1926.760 would apply. leading edge However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." Question (2): Assuming the same scenario set forth in the first paragraph of Question (1), can controlled access zones be used for residential roofing activities when the roof slope is greater than 4 feet vertical to 12 feet horizontal? Your letter was forwarded to this office for handling on April 7, 2003. Compliance of using warning lines and/or control access zones for fall protection on roofs with a slope greater than 4:12. (1) When used to control access to areas where leading edge and other operations are taking place, the controlled access zone shall be defined by a control line or by any other means that restricts access. We apologize for the delay in responding. This letter constitutes OSHA's interpretation of the requirements discussed. In such a setting, can a roofing contractor use controlled access zones or warning lines when engaged in roofing activity on a roof with a slope greater than 4 feet vertical to 12 feet horizontal? The control lines used to define the controlled access zone must be between 6 feet and 25 feet from the leading edge and must be attached on either end to a wall or guardrail system. The lines are erected as a controlled access zone by an authorized employer (either a … Re: Whether warning lines and/or control access zones can be employed for roofing work (residential and non-residential) on roofs with a slope greater than 4:12 Some types of metal roofing are installed over a roof deck. 40695 the Preamble emphasizes: In sum, §1926.501(b)(13) presumes feasibility. Directorate of Construction, 1 STD3-01.A is the plain language rewrite of STD3.1, issued December 8, 1995, which in turn superseded, with respect to residential construction, the July 12, 1995, fall protection enforcement policy memorandum of Deputy Assistant Secretary James W. Stanley. The U.S. Occupational Safety and Health Administration (OSHA) requires employers to maintain fall protection safety measures to protect employees in … This activity may be performed in a controlled decking zone as noted in Section 1926.760 Fall Protection: in Appendix D to this subpart. Section 1926.500 defines leading edge activity in terms of a structural surface that forms an edge that advances/changes as additional sections are installed: The roofing work you describe (installing a weather-proofing material over a roof deck) is not within that definition, since it is not a structural surface that forms an edge of a walking/working surface. [ back to text ], 3 See Question (3) below for a discussion of the conventional fall protection provided for in the Standard for "Steep roofs." Question (3)(a): We are interested in the availability of alternative fall protection for roofing activities (such as tile, shingle, tar and felt) in the nonresidential construction arena (work not covered by STD 3-0.1A). Controlled-access zone: an area in which certain work (e.g., overhand bricklaying) may take place without guardrail systems, personal fall arrest systems, or safety net systems. VerticalScope Inc., 111 Peter, Suite 901, Toronto, Ontario, M5V 2H1, Canada. The control line must be approximately parallel to the unprotected or leading edge. We have paraphrased your questions below: As outlined below, those circumstances, as relevant to your question, are affected by the following three factors: the activity involved (e.g., roofing); the slope of the roof; and the nature of the work (e.g., residential). [ back to text ]. Also addressed are controlled access zones, safety nets, and guardrail, personal fall arrest, warning line, and positioning device systems. Either of the following is met: a. 21.A.04 When using stilts, or working from raised platforms or floors above a d.Warning Line System. Answer Mr. Michael C. Wright, PE, CSP, CPE 1926.502(g): Controlled access zones only apply to overhead bricklaying and related leading-edge work. a. Under Subpart M, only certain types of work may be performed in a CAZ. It is a permanent warning lines system that shares the same 108 lb bases as the Safety Rail 2000 guardrails. 40682: However, at 59 Fed. Warning lines are used to demarcate safe working areas on an elevated working surface. September 26, 2003 *No. [ back to text ], 8 It should be noted that the definition of "Steep roof" and the conventional fall protection delineated in this Section would have equal application to the residential roofing activities referenced in Questions (1) and (2). You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. Conventional fall protection under Part 1926 Subpart M is required for this type of work (unless it were done in conjunction with steel erection work).9 When using controlled access zones while performing overhand bricklaying and related work: 1.Additional control lines must be erected at each end to enclose the zone. It provides in part: Section 1926.500 defines "Low-slope roof" as: Thus, the intended residential roofing activities on roofs with a slope greater than 4 in 12 would not meet the stated criteria of these sections that allow for the use of a warning line system.3 As §1926.501(b)(10) is the only provision that specifically provides for the use of a warning line system (in conjunction with another system) as fall protection for roofing activities, the employer here cannot use such a system unless another provision in the Standard or the Directive applies. You ask about the use of warning lines or controlled access zones as fall protection for employees engaged in certain roofing activities. Answer OSHA's fall protection standard for construction, 29 CFR Part 1926 Subpart M (Fall Protection) ("Standard"), as well as its related Directive Number STD 3-01.A ("Directive")1 generally require[s] conventional fall protection (guardrail systems, personal fall arrest systems, or safety net systems) for work where there is a fall distance of 6 feet or more. Definition ; Controlled access zone (CAZ) means an area in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled. (g) Controlled access zones. For a better experience, please enable JavaScript in your browser before proceeding. Question 1(b):*Would it be permissible to use warning lines 6 feet back from the edge and designate the area inside the lines as a Controlled Access Zone (CAZ) instead of providing conventional fall protection for these workers while within the CAZ? Our response to your company's question regarding the potential use of "controlled access zones" in conjunction with residential roofing activities parallels our answer to Question (1). Reg. The PermaLine is one of the best rooftop warning flag systems available. [ back to text ], 9 If this were done during and as part of a steel erection activity (§1926.750(b)(1)), then this work would be covered under the steel erection standard under §1926.750(b)(2). Controlled access zones (1926.502(g)) have applications that stretch beyond just an employee’s fall protection, but are applied to guard/warn against falling objects (i.e. A forum community dedicated to professional roofers and enthusiasts. No. When controlled access zones are used to limit access to areas where overhand bricklaying and related work are taking place: A control line must be erected to define the work zone and must be erected at least 10 feet and no more than 15 feet from the working edge. But there is an often overlooked secondary use for Fall Prevention systems: the establishment of a controlled access zone. Note that 1926.751 defines "controlled decking zone" as: In sum, the use of control lines as part of a controlled decking zone is permissible for metal roofing activity that falls within §1926.750(b)(1) of the Steel Erection Standard. The Controlled Access Zone (CAZ) is separated from the Safe Zone by a heavy control line that restricts access to the CAZ. Roofing Talk - Professional Roofing Contractors Forum. * * * Note that our enforcement guidance may be affected by changes to OSHA rules. Answer Question 1(b):*Would it be permissible to use warning lines 6 feet back from the edge and designate the area inside the lines as a Controlled Access Zone (CAZ) instead of providing conventional fall protection for these workers while within the CAZ? The employer has effectively implemented a work rule prohibiting going past the warning line, and 3. The activity is also not leading edge work (§1926.501(b)(2)). Managing Principal JavaScript is disabled. Use of a “Warning Line System” is limited to roofing work on low-sloped roofs and must be used in combination with a “Safety Monitoring System.” Use of a “Safety Monitoring System” alone is limited to low-sloped roofs with a width of 50’ or less. As mentioned earlier, the roofing work also does not fall under §1926.502(k) as precast concrete erection work or leading edge work. Ensure the control line is connected on each side to a guardrail system or wall. PO Box 20246 [ back to text ]. Question (1): 29 CFR 1926.500-1926.503 and OSHA Directive Number STD 3-01.A set[s] forth OSHA's requirements with regard to fall protection for certain residential construction activities, including roofing. 10 Section 1926.751 defines "Leading edge" as: Occupational Safety & Health Administration, Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. Make sure the controlled access zone is defined by a control line or by any other means that restricts access, and make sure signs are posted to warn unauthorized employees to stay out of the controlled access zone. Thus, under the standard, warning line systems may be used as fall protection for some types of roofing work.2 However, as discussed below, a roof's slope and the residential nature of the work may affect the availability of this fall protection. Access to the zone is controlled. As summarized in the Preamble at 59 Fed. Personal fall arrest system: a system used to stop an employee’s fall. Subpart R, Steel erection (not covered in this article) allows other applications. Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. OSHA requirements are set by statute, standards and regulations. They can only be used as legitimate fall protection measures under certain conditions. [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. Section 1926.501 defines a warning line as: Section 1926.502 (fall protections systems criteria and practices) provides: Significantly, the definition and the referenced §1926.501(b)(10) both refer to or relate to roofing work. Protecting workers from falling objects 7 V. Training workers about fall protection 8 Retraining 8 Documenting training 8 VI. However, unlike a warning line, which is barrier that cannot be crossed, a controlled access zone establishes a boundary that can be crossed, but only by a specifically designated employee. Some types of metal roofing serve as the roof structure or metal decking (there is no structural decking below it). Question 3(b): What about for metal roofing? Section XII of the Directive sets forth alternative fall protection systems for certain defined residential roofing work.5 However, it does not include warning line systems as an alternative. Controlled-Access Zones. Answer The Ladder Access Guardrail meets and exceeds standards and requirements for controlled access zones. Section 1926.500 defines a "Controlled Access Zone" ("CAZ") as: Particular requirements associated with its use are delineated in §1926.502(g). The Standard does not permit the use of controlled access zones, warning lines, or other alternative fall protection methods for nonresidential roofing activities on steep roofs. Russell B. Swanson, Director 1926.502(f): Warning line systems only apply to roofing work on low-slope roofs. Rather, the alternative fall protection systems listed are limited to safety monitors and slide guards. 2.The zone must be enlarged to enclose all points of access, material handling areas and storage areas if guardrail systems are not in place. OSHA's construction fall protection standard, which was revised in 1989, addresses a host of innovative fall protection methods, including personal fall arrest systems, controlled access zones, warning line systems and safety monitoring systems. As such, the Directive does not provide a basis for an employer's use of a warning line system. 40692, this Section, entitled "Residential construction" requires: The Preamble continues at 59 Fed. Are controlled-access zones where . Here is a question from another employer about CAZ and an answer from OSHA through a letter of interpretation, hope this helps answer your question. We assume for the purposes of this response that the work to be performed is within the purview of [that] definitions. Fall Prevention systems, such as guardrails and warning lines, are awesome tools; they are simple to understand, easy to set up, and, when fully installed, completely obstruct access to fall hazards. Given the regulatory history and the presumptions set forth in the Standard, the potential for use of warning lines in this instance appears to be remote. The installation of such decking is leading edge work10 and is included in the steel erection standard (Part 1926 Subpart R) as a steel erection activity under §1926.750(b)(1). If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. Specifically, the referenced §1926.501(b)(10) limits the use of warning lines to low-slope roofs. [ back to text ], 7 The previous discussion on "feasibility" in footnote 3 is equally applicable here. 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