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Fall protection citation for roofing operations

Summary A steel erection company asked how OSHA's open-side floor rule applied to roofing operations in light of court and commission decisions. OSHA said that provision should not be cited for roofing work, while other fall protection provisions could apply to certain work outside the rule's built-up roofing definition. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1984-03-21
Date issued
March 21, 1984
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1926 Roofing Fall Protection Enforcement
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 21, 1984

Mr. Frank G. Goldenberg
Erection Department
Montague-Betts Company
[Recipient address omitted]
Dear Mr. Goldenberg:

This is in response to your letter of March 5, concerning the application of 29 CFR 1916.500(d)(1) in view of two U.S. Court of Appeals decisions and an Occupational Safety and Health Review Commission decision.

We have been informed by the Office of the Solicitor of Labor that 29 CFR 1926.500(d)(1) should not be cited for any roofing operation. However, 29 CFR 1926.28(a) or 29 CFR 1926.105(a) may be applicable for certain roofing operations which do not fall within the 29 CFR 1926.500(g) definition of "built-up" roofing work.

If we can be of further assistance, please let us know.

Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

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