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The answer depends on which OSHA standards apply to the specific work situation. In federal OSHA’s general industry (1910 standards), the general rule is that suitable fall protection is required to be provided and used when a worker near the side or edge of, or opening in, a walking-working surface is exposed to a potential fall of four (4) feet or more. However, the general industry scaffold standard for general industry requires fall protection be provided and used at 10 feet. There is also a standard that requires fall protection be used anytime an employee is working above dangerous equipment regardless of the height. Last but not least, there is a specific rule requiring suitable fall protection on fixed ladders that extend more than 24 feet above a lower level.

For construction environment (1926), federal OSHA standards generally require suitable fall protection be used when an employee is exposed to a potential fall of six (6) feet or more when working at the edge or side of, or opening in, a walking-working surface. The scaffold standard for construction requires fall protection be provided at 10 feet. There are also special rules for employees working in steel erection activities; fall protection is required to be provided and used when exposed to potential falls of 15 feet or greater for most workers, and at 30 feet or greater for connectors.

This is a general, non-exhaustive overview of federal OSHA fall protection thresholds that apply to many work situations. However, there are several other requirements in both the general industry and construction standards that require fall protection for other specific situations. And remember that some state OSHA programs could have different requirements that are more restrictive, as do other government agencies (such as the US Army Corp of Engineers EM-385-11 standards) and some companies. Always refer to, and comply with, the applicable standards for your specific work situation and location.

Federal OSHA 1926 Construction Fall Protection Requirements, which apply to most contractors working on worksites regulated by OSHA, and the EM-385-1-1 Fall Protection Requirements, which apply to workers on jobsites regulated by the US Army Corp of Engineers (USACE). Many of the two organizations’ fall protection-related standards are the same or substantially similar. However, there are a few important differences that are often overlooked. Here is a non-exhaustive overview of the major differences:

As mentioned above, federal OSHA 1926 construction fall protection standards generally requires construction workers to be provided with some form of fall protection (e.g.: guardrails, safety nets, personal fall arrest system . . .) when exposed to falls of six (6) or more feet. OSHA standards also has exceptions for construction workers who are on a scaffold (10-foot threshold for fall protection), and iron-workers involved in erecting steel (15 threshold for most activities, 30 feet for connectors in certain instances).  However, the EM-385 rule that apply to US Army Corp of Engineer job-sites applies the six (6) foot fall protection rule to most all workers on their worksites, and specifically state they require fall protection be provided for workers using scaffold as well as iron-working at the six-foot threshold.

Another commonly overlooked difference is that OSHA construction standards only address use of a body belt to be used by workers in extensible boom lifts, and they do not address or require the same for workers in scissor lifts. But the EM-385 rules do require employees in scissor lifts also wear a body belt or harness equipped with a lanyard short enough to prevent them from leaving the platform.

One more primary difference is that the OSHA fall protection standards do require employers provide for timely rescue of employees who have fallen and are suspended in a full body harness, whereas the EM-385 rule followed on US Army Corp of Engineer job-sites also requires the employer to develop and have on site a written fall protection plan which includes written procedures (not required by OSHA) to be used for fallen worker rescue.

Refer to federal OSHA 1926 construction standards and the US Army Corp of Engineers EM-385-1-1- standards for full details about their respective requirements.

Generally speaking, Fall Prevention is the term used to classify items such as guardrails and travel restraint systems that prevent a worker from falling. A Fall Protection system protects the worker from striking the ground or other lower work surface by arresting (stopping) the fall once it has occurred; for example, a full-body harness with lanyard attached to an anchor, or a safety net system.

Generally speaking, no; the employer will need to provide some form of fall protection, such as but not limited to a fall arrest system, guardrails, safety net, hole cover, or travel restraint system, for affected workers. However, federal OSHA general industry standards do allow some employees to perform certain types of work while on low-slope roofs (no more than a 1 to 4 vertical to horizontal slope) without using any form of fall protection, but only if the work is performed both infrequently and is temporary in nature. In those infrequent cases, the employer must implement and enforce a work rule prohibiting employees from going within 15 feet (4.6 m) of the roof edge without using fall protection. Because this is a general, non-exhaustive overview of fall protection requirements for general industry, you must refer to 1910 Subpart D for specific federal OSHA requirements.

There is also a rule in the federal OSHA construction standards that allow some employees to perform specific types of work on low-slope roofs with a 34- to 39-inch-high flagged warning line installed six or more feet back from the edge. They may also work closer to the edge when a trained designated safety monitor is present to observe the workers and warn them if they appear to be approaching the edge unknowingly or working unsafely. However, this allowance is ONLY applicable to non-residential roofing work (such as installing or removing commercial roofing materials; NOT just being on top of a roof while working). A similar option is also available to workers performing over-hand brick-laying work or pre-cast panel erection. Because this is a general, non-exhaustive overview of fall protection requirements for construction, you must refer to 1926 Subpart M and associated standards for specific federal OSHA requirements.

No. The federal OSHA standard that outlines the scope of fall protection regulations for construction, found in 1926 subpart M, specifically exclude portable ladders from coverage by those rules; ladder use is instead regulated by federal OSHA in 1926 subpart X, which does not require use of a fall protection system when using a portable ladder. The same is true for general industry, as found in paragraph 1910.28(a)(2)(i). Be aware that some state standards, or those of other government agencies or private companies, may still require use of some form of fall protection while working on a portable ladder, or on other types of ladders (e.g.: fixed ladders, mobile ladder stands and platforms), so always research all applicable regulations for your work environment.