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Interim fall protection policy for roofing work

Summary OSHA told field offices how to cite fall-protection violations in steep-roof and built-up roofing work while a new construction rule was pending. The memorandum limited citations to failures under two cited provisions and said other authorities should not be used below a 16-foot fall distance during that interim period. OSHA archives the memo and warns it may no longer represent current policy.
Document
Federal guidance
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-06-13-0
Date issued
June 13, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy; the memorandum expressly applied only until publication of the new Subpart M.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1926 Fall Protection Roofing
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent current policy; the memorandum expressly applied only until publication of the new Subpart M. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 13, 1994

MEMORANDUM FOR: OFFICE OF FIELD PROGRAMS
REGIONAL ADMINISTRATORS

FROM: JAMES W. STANLEY
DEPUTY ASSISTANT SECRETARY

SUBJECT: Fall Protection for Steep Roofs and During the Performance of Built-Up Roofing Work

Until new subpart M--Fall protection is published, the interim policy regarding fall protection during roofing operations is as follows:

Citations for failure to use fall protection shall be issued to employers engaged in steep roof or built-up roofing activities only when those employers are not in compliance with the requirements of 29 CFR 1926.451(u)(3) for work on steep roofs, and 29 CFR 1926.500(g) for work during built-up roofing operations. Section 5(a)(1) of the Act and 29 CFR 1926.95(a) shall not be used to require fall protection during those operations when the fall distance is less than 16 feet.

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