Safety monitors on low-pitch roofing work

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 8, 1988

MEMORANDUM FOR: FRANK STRASHEIM
Regional Administrator

THRU: LEO CAREY, Director
Directorate of Field Programs

FROM: THOMAS J. SHEPICH, Director
Directorate of Compliance Programs

SUBJECT: Interpretation of Fall Protection Requirements on Construction Sites.

In response to acting Deputy Regional Administrator, Thomas Marple, I am providing a clarification of the circumstances where a safety monitor may be used in lieu of a motion-stopping-safety system (MSS system) on construction sites.

Under current OSHA regulations the only place where a safety monitor may be used in lieu of a MSS is during built-up roofing operations on low pitched roof perimeters. The record is clear that the safety monitor was not the preferred means of protection and was intended only for circumstances where it was not possible to provide other means of physical fall protection. Although the standard does permit a monitor for built-up roofing work, employers are also required to provide specific training for employees engaged in the work to enable them to recognize and avoid the hazard of falling. The safety monitor system was intended to apply in special cases as referenced in 29 CFR 1926.500(g)(1)(ii) and 29 CFR 1926.500(g)(1)(iii). In fact, 29 CFR 1926.500(g)(5) required a MSS system under those conditions where it is anticipated employees will be required to work at the immediate edge of the roof such as when employees are engaged in roof edge materials handling and material storage.

With regard to the question of whether or not an employee working alone can be his own monitor, the standard does not address this issue. The supplemental information makes it clear that, although an employee may have other duties in addition to monitoring, the work cannot be such that it would cause the monitoring function to be encumbered.

If we can provide further guidance on this matter please let me know.