In 1994, the Occupational Safety and Health Administration (OSHA) issued Subpart M—Fall Protection in its construction industry regulations. In it were new requirements that were, to say the least, unsettling for the roofing industry. Foremost was the new requirement to provide fall protection whenever a fall distance is 6 feet or more above a lower level. Previously, the trigger height was 16 feet.
Since 1994, the roofing industry generally has adapted to the federal 6-foot trigger height though a number of states, for example California and Oregon, have trigger heights that exceed the 6-foot federal OSHA requirement. Other state-plan states also provide differing fall-protection options from the federal requirements. These regulatory variations contribute to the lack of consensus about which fall-protection options best protect workers partly because there are so many variables on every roofing project to consider.
Shortly after Subpart M was published, NRCA approached OSHA regarding the standard's application to steep-slope roofing work, specifically residential roofing work. OSHA defines steep-slope roofs as those with slopes greater than 4:12 (18 degrees). The roofing industry was concerned fall-protection options for work on steep-slope roofs were too limited and did not provide sufficient roofing worker protection. The regulation only allowed for personal fall-arrest (PFA), guardrail and/or safety-net systems, which OSHA defines as conventional fall-protection options.