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Oregon residential roofing fall protection policy

Summary OSHA reviewed Oregon’s residential roofing fall-protection policy under its state-plan oversight role. It concluded that Oregon’s policy allowed work at greater heights and roof pitches without the protection required by the then-current federal standard, so it was less effective. OSHA archives the memorandum and warns it may no longer represent current policy.
Document
Federal guidance
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-04-21-0
Date issued
April 21, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1926 Fall Protection State Plans
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent current policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 21, 1994

MEMORANDUM FOR: ZOLTAN BAGDY, Acting Director
Federal-State Operations

FROM: H. BERRIEN ZETTLER, Deputy Director
Directorate of Compliance Programs

SUBJECT: Oregon Fall Protection Policy for Residential Construction

This is in response to your March 15 request for DCP review of Oregon's fall protection policy for residential construction.
We have reviewed Oregon's fall protection plan and their response to the Region's Complaint About State Program Administration (CASPA 0-146) and we agree with the Region's conclusion that Oregon's policy related to fall protection for workers engaged in sheathing and roofing installation in the residential construction industry is less effective than Federal requirements. Federal standards require that when roof brackets are used, roofs more than 16 feet from the ground to eaves with a slope greater than 4:12, without a parapet, be provided with a catch platform unless the employees are protected by a safety belt attached to a lifeline. Oregon's policy allows employees to work from roof brackets on roofs with ground to eave heights between 16 feet and 25 feet without catch platforms or safety belts and lifelines. Oregon's policy allows employees to work without fall protection on higher pitched roofs and at greater heights, than do Federal Regulations. Therefore, we conclude that Oregon's fall protection policy is not equivalent to the Federal.
If we can be of any further assistance, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

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