Fall protection atop residential concrete formwork

OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

July 1, 1999

MEMORANDUM FOR: EDWARD KASSAK
DAVE HERSTEDT
REGION VIII-FSO

FROM: RUSSELL B. SWANSON, DIRECTOR
DIRECTORATE OF CONSTRUCTION

SUBJECT: James Naylor letter of April 20, 1998

In your letter, dated December 7, 1998, you asked that we respond to two questions regarding the fall protection requirements for working on top of formwork in residential construction.

In residential construction, when employees are standing on top of concrete formwork with a fall hazard in excess of six feet, is conventional fall protection required?

In residential construction, under STD 3.1 [superseded by STD 3-0.1A], conventional fall protection is not required for workers working from the top of foundation wall formwork. The letter to Mr. Naylor did not address residential construction and did not address working from the top of formwork.

When employees are standing on top of concrete formwork, (typically on a 2x4 waler) must the surface the employee is standing on be at least 18 inches wide in accordance with Subpart L? If so, are standard guardrails required if the fall distance is greater than 10 feet?

Under STD 3.1, the scaffold requirements do not apply to the top of concrete formwork while the employee is constructing the wall. The Naylor interpretation letter, dated April 20, 1998, dealt with a 2x4 waler attached to the face and about half way up the formwork.

Should you have further questions, please don’t hesitate to write to: Directorate of Construction- Office of Construction Standards and Compliance Assistance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210.