The enforcement date has arrived for residential contractors to comply with OSHA’s STD 03-11-002. This directive, which went into effect March 15, cancelled the previous guideline, which had been in effect since 1999. It contains new and somewhat controversial residential fall protection guidelines for every contractor engaged in residential construction.
The directive requires that employers comply with 29 CFR, 1926.501(b)(13) and provide conventional fall protection, which typically means guardrail systems, safety nets or personal fall arrest systems (PFAS). There are some exceptions, including cases where the employer can clearly and concisely demonstrate these systems are infeasible or pose a greater hazard, but the new instruction essentially eliminates the alternate methods (including slide guards, controlled access zones and competent safety monitors) as the primary means of fall protection for roofing contractors engaged in certain residential construction activities.