Enforcement Policy for Residential Fall Protection

Read this informative article about changes in residential construction requirements.

Dave Lucas, CIC

The revised CSHD-COM-04-1R1, Residential Fall Protection Compliance Criteria, will be in effect Thursday, June 16, 2011.  Under the revised instruction, employers engaged in residential construction activities must comply with Part 45 – Fall Protection, Rule 1926.501(b)(13).  If the employer can prove infeasibility or a greater hazard, they are allowed to implement a fall protection

plan.  The plan must be in writing and site-specific.  The definition of “residential construction” was also revised and will now only apply to construction work that

meets both of the following two elements:

(1) The end-use of the structure being built must be as a home, i.e., a dwelling.

(2) The structure being built must be constructed using traditional wood frame construction materials and methods.

On April 4, 2011, MIOSHA and the Michigan Home Builders Association launched a Residential Fall Protection Initiative with the purpose of working together to provide training and help residential builders come into compliance with 1926.501(b)(13) and the revised instruction.

To allow the residential industry adequate time and resources to comply with the revised instruction, MIOSHA will adopt the following guidelines for an additional six (6) months, from June 16, 2011 through December 16, 2011, for alleging violations for residential fall protection:

  • For inspections where employers are fully in compliance with the former CSHD-COM-04, MIOSHA will issue a Potential Hazard Alert (PTA) addressing the requirements of the revised CSHD-COM-04-1R1 and training. This will apply only to the first inspection during the additional 6 month period.
  • For inspections where employers are attempting to comply with the revised CSHD-COM-04-1R1 by using conventional fall protection systems, however the systems are not fully in compliance; MIOSHA will issue a Potential Hazard Alert (PTA) addressing the requirements of the revised CSHD-COM-04-1R1 and training. This will apply only to the first inspection during the additional 6 month period.
  • For inspections where employers are using a site-specific fall protection plan when conventional fall protection is feasible and does not create a greater hazard, MIOSHA will assist the employer in feasible methods of fall protection that could be used in lieu of the site-specific fall protection plan and issue a Potential Hazard Alert (PTA) addressing the requirements of the revised CSHD-COM-04-1R1 and training. This will apply only to the first inspection during the additional 6 month period.
  •  For inspections where conventional fall protection is not in place or employees are not in compliance with the former CSHD-COM-04 or another fall protection plan, MIOSHA will issue appropriate citations.
  • No citations will be issued for inspections where employers are using site-specific fall protection plans that appropriately evaluate infeasibility or a greater hazard to use conventional fall protection systems.
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