The Fall-Protection Threshold on a Small Roof Job
A three-person crew is replacing shingles on a single-story ranch house. The eave is 9 feet 6 inches above the ground on the downhill side and 11 feet above grade on the uphill side because the lot slopes. The employer has no written fall-protection plan and no harnesses on site. The foreman says, "It's under 10 feet, so we're fine - OSHA only cares above 10." A worker asks whether the sloped ground changes anything. The crew plans to work within 6 feet of the eave all day, and there is no guardrail, safety net, or personal fall-arrest system available. The general contractor's site safety rep is scheduled to visit in two hours.
1. Is the foreman's "under 10 feet" reasoning correct for this job? Explain the actual trigger and how the sloping grade affects the analysis.
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No. The 10-foot figure the foreman is quoting applies to general industry (29 CFR 1910) and is not the construction rule. Under the construction standards (29 CFR 1926 Subpart M), conventional fall protection - guardrail systems, safety net systems, or personal fall-arrest systems - is required when employees are exposed to a fall of 6 feet or more to a lower level, and also when working near certain dangerous edges regardless of height. The relevant measurement is the vertical distance from the walking/working surface to the lower level directly below the work area, not a single number for the whole roof. On the uphill side the drop is 11 feet and on the downhill side 9 feet 6 inches - both exceed 6 feet, so fall protection is triggered on both sides. The foreman is applying the wrong threshold and the wrong measurement point. The sloping grade does not create an exemption; it actually means the exposure is higher on one side than the crew may assume.
2. What should happen before work resumes, and what is the general contractor's exposure if the crew continues as planned?
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Work should stop until a fall-protection system is in place. Options include a guardrail system along the eave, a safety net, or a personal fall-arrest system with appropriate anchorage, harnesses, lanyards, and a rescue plan. Because the crew is working within 6 feet of the eave, they are exposed to the edge, so simply "staying back" is not a substitute for a system. The employer also needs a written fall-protection plan if fall arrest is used, and workers must be trained on the equipment. The general contractor, as the controlling employer on a multi-employer site, can be cited for failing to exercise reasonable care to detect and correct the hazard even though the roofing sub employed the workers. Leaving the crew on the roof without protection after the safety rep's visit would expose both the roofing employer and the GC to willful or repeat exposure depending on history.