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Fall-protection plans for residential framing work

Summary An OSHA regional office asked whether builders could use fall-protection plans for certain framing tasks and across multiple similar home sites. OSHA said walking an interior wall sill between braced trusses could be covered by a plan with precautions, that a plan could be used for erecting second-floor walls, and that one plan could cover sites with similar hazards. OSHA now labels the response an archive document.
Document
Federal interpretive notice
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-09-26
Date issued
September 26, 1995
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 26, 1995

MEMORANDUM FOR: MICHAEL G. CONNERS, Regional Administrator
Chicago Regional Office

THROUGH: JOHN B. MILES, JR., Director
Directorate of Compliance Programs

FROM: ROY F. GURNHAM, Director
Office of Construction and
Maritime Compliance Assistance

SUBJECT: Fall Protection

Enclosed is the Occupational Safety and Health Administration's response to your memorandum of March 28 concerning several questions relating to fall protection based on discussions with Regina Solomon with the National Association of Home Builders. Because of a large backlog of correspondence, this office was not able to respond to you as quickly as we would have liked. Please accept my apologies for any inconvenience this delay may have caused.
September 26, 1995

MEMORANDUM FOR: MICHAEL G. CONNERS, Regional Administrator
Chicago, Regional Office

THROUGH: John B. Miles, JR., Director
Directorate of Compliance Programs

FROM: ROY F. GURNHAM, Director
Office of Construction and
Maritime Compliance Assistance

SUBJECT: Fall Protection

This is in response to your March 28 memorandum in which you raised several questions relating to fall protection based on discussions with Regina Solomon with the National Association of Home Builders.
You inquired as to whether employees erecting roof trusses are allowed to walk the top sill without using fall protection, provided they are working between already erected and braced trusses. Yes, this procedure is allowed for interior wall sills provided the company's fall protection plan discusses how to perform this procedure and all safety precautions to be taken.
You also asked if employees erecting second floor walls can utilize a fall protection plan in lieu of conventional fall protection systems. Yes, it is permissible to use a fall protection plan for the operation of erecting second floor walls.
In addition, you asked if one fall protection site plan can cover different model homes under construction on a large development, and, if a contractor is building the same model home at different locations, can one site plan cover all locations. The answer is yes to both questions. Fall protection plans need to be site specific only to the extent that they address the fall hazards present at that site. One plan can cover several sites if similar conditions exist at all sites.
If you have any questions, please call me or Dale Cavanaugh of my staff at (202)219-8136.

[Original regional request reproduced on OSHA page; omitted here.]

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