October 2012

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Steel erection standard may apply to fall hazards

Roofing contractors generally refer to the Occupational Safety and Health Administration's (OSHA's) Subpart M, 29 CFR §1926.500-503, for information regarding fall-protection issues involved in roofing work. However, in certain instances, Subpart R, OSHA's steel erection standard, may apply to fall hazards during some roofing work.

Subpart R applies to employers "engaged in steel erection," and some roofing activities are covered by this subpart when they "occur during and are part of steel erection activities." Such activities include metal roofing and accessories, architectural and ornamental metal work, and skylights. Workers engaged in steel erection activity on a walking and/or working surface with an unprotected side or edge greater than 15 feet above a lower level must be protected by guardrails, personal fall-arrest systems, safety nets, fall-restraint systems and/or positioning device systems.

Additionally, a controlled decking zone (CDZ) may be established in an area of a structure more than 15 feet and up to 30 feet above a lower level where metal decking initially is being...

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