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

June 4, 2024

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? Do you assess with your plain eyes or apply relevant regulatory rules?

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, federal Occupational Safety and Health Administration (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. Let’s dig deeper into specific OSHA rooftop fall protection requirements.

OSHA Guidelines

OSHA has detailed several requirements to protect workers in construction, general industry workplaces, or when working with dangerous equipment. The two most important guidelines for fall protection in the construction industry are:

OSHA 1926.501(b)2i

According to OSHA 1926.501(b)2i guidelines, the employer must protect employees constructing leading edges 6 feet or more above a lower level. The means of protection can include safety net systems, guardrail systems, or personal fall arrest systems. The exception to these guidelines is when the employer can prove that it’s not feasible to use these fall protection systems or that using them will create greater hazards. Still, the employer will be required to develop and implement a fall protection plan that meets other OSHA requirements.

OSHA 1926.501(b)2ii

Employers must also protect employees on a working or walking surface 6 feet or higher over a lower surface if the leading edge is under construction, even if they aren’t actively involved in leading-edge work. Similar to 051(b)2i, OSHA 1926.501(b)2ii specifies that means of protection can include a safety net system, guardrail system, or personal fall arrest system.

Clarification on the 6-Foot Rule

Although OSHA does not expressly state that there is a 6-foot rule, many industry safety experts, some OSHA inspectors, and employers have followed the rule. In Secretary of Labour v. Precast Company, the Occupational Safety and Health Review Commission held that no such rule exists. Instead, the commission held that fall protection must be provided only when it is reasonably predictable that workers will be in the danger zone – or have been in the danger zone – the standard was designed to prevent. 

Choosing Fall Protection for Ledge Work

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 repairing 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.

Factors to Consider in Choosing the Right Fall Protection System

The following factors are key when selecting a fall protection system for leading edge fall protection:

  • Compliance with OSHA standards: The fall protection system should fully meet OSHA standards. Confirming compliance ensures you have the right equipment that guarantees your workers’ safety while avoiding penalties for OSHA violations. 
  • Budget: Your budget is also a significant factor in choosing the fall protection system for your team. More complex systems are often more expensive, but meeting safety requirements for your workers means going for the right equipment regardless of the cost.
  • Know your needs: Needs for different projects may vary. What’s necessary for rooftop fall protection may be different from what’s needed for sites at a lower level. Assess the workplace and your team to determine which safety equipment you’ll need. For example, you need to know precise measurements of the fall distance.
  • Flexibility and ease of use: Flexibility mainly applies to wearable fall protection equipment. Be sure to consider flexibility and comfort. The gear should also be user-friendly.
  • Reputation of the vendor: Always buy your equipment from top brands like Rigid Lifelines. Consider a vendor with industrial-grade options and a competent team to guide you in purchasing. 
  • Repairs and inspections: All fall protection systems need maintenance, inspections, and repairs. Inspect the equipment annually and after a fall. Some systems can withstand falls with minimal or no damage. However, some will need repairs or even replacement after a fall.

Questions You Should Ask

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

  1. Is the surface level or pitched?
  2. Is the surface compromised?
  3. Does the surface contain fall hazards other than edge work, such as holes or shaftways?
  4. How slippery is the surface?
  5. What is the expected duration of the job?
  6. What are the likely weather conditions during the job period?

Get the Right Fall Protection Solution

Are you looking for rigid rail fall protection systems? At Rigid Lifelines, we engineer, design, and test rigid rail fall protection systems that comply with ANSI Z359, OSHA 1926, and OSHA 1910 standards. Our systems can make you, your employees, and your clients safer. You can also find a rep in your area for quick fall protection solutions in your region. 

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