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
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