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.
In response to comments issued by NRCA explaining that conventional fall-protection options are not always the most effective for protecting workers in certain residential applications, OSHA considered adding an appendix to Subpart MAppendix F: Residential Fall Protection Plan for Roofing Work.