In August 1994, the Occupational Safety and Health
Administration (OSHA) issued new fall-protection regulations known
as Subpart M. The regulations reduced the fall-protection trigger
height from 16 to 6 feet, which affected all roofing contractors
performing residential (steep-slope) work. It meant roofing work on
virtually every structure required workers to use one of three
conventional types of fall protection: guardrails, safety nets or
personal fall-arrest systems.
The regulations allowed for using written site-specific
fall-protection plans instead of conventional fall-protection
methods if the employer could show such methods were infeasible or
created a greater hazard. The burden with this option was proving
infeasibility or greater hazard for every project, no matter how
small or short-term.
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