How Close is Too Close? Leading Edge Work and Fall Protection

A significant number of fall-related injuries and deaths occur annually due to falls from unprotected roof edges. But how do you assess what type of fall protection best fits the job?

A common rule of thumb in the construction industry is “the 6-foot rule,” i.e., that a worker on a flat surface more than 6 feet from an unprotected edge does not require fall protection. However, OSHA regulations include NO SUCH RULE. State OSHA guidelines may vary, but in NO CASE is mere distance from an edge considered sufficient protection when a fall hazard of over 6 feet to a lower level exists.

So, when working at height, workers must have some protection from falls from a leading (unprotected) edge. OSHA is clear on this point.

OSHA 1926.501(b)2i states:
“Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems.”

Similarly, OSHA 1926.501(b)2ii states:
“Each employee on a walking/working surface 6 feet (1.8 m) or more above a lower level where leading edges are under construction, but who is not engaged in the leading edge work, shall be protected from falling by a guardrail system, safety net system, or personal fall arrest system.”

That still leaves the problem of choosing an appropriate and cost-effective solution. Common sense usually dictates the type of fall protection that is sufficient. For example, if workers are engaged in a short-term task, such as repair of a rooftop HVAC unit that is 15 feet from the nearest unprotected edge, a temporary guardrail system may be the fall protection system most appropriate for the job. However, if workers are repairing a storm-damaged roof surface 6 feet from the nearest unprotected edge, a more aggressive fall protection system, such as a building framework barrier system that allows for self-rescue, may be more appropriate. Workers on a pitched or non-level roof, however, would require the most robust form of fall protection—either anchored to a fixed point or trolley-anchored—with a lanyard and full-body harness.

It is important when choosing the most appropriate fall restraint system for leading edge work to consider several factors, other than the distance of the potential fall and the distance between a worker and the nearest unprotected edge.

Questions to ask when assessing the type of fall protection required include:

– Is the surface level or pitched?
– Is the surface compromised?
– Does the surface contain fall hazards other than edge work (i.e., holes or shaftways)?
– How slippery is the surface?
– What is the expected duration of the job?
– What are the likely weather conditions during the job period?

Your manufacturer representative can help you choose the best fall protection system for the job. Feel free to contact your representative with any questions and for a full description of available fall prevention and fall restraint products.