Written Fall Protection Plans
In construction, the default is conventional fall protection: guardrails, safety nets or personal fall arrest. A written fall protection plan is a narrow exception for a few kinds of work where the employer can show conventional protection is infeasible or creates a greater hazard. It’s not a shortcut.
- Construction
Where a plan can be used
- Leading edge work
- Precast concrete erection
- Residential construction
For residential work, OSHA presumes conventional fall protection is feasible. The employer has to prove it isn’t for each specific task. See Residential Fall Protection.
What the plan must include
- Prepared by a qualified person for the specific site; changes approved by a qualified person
- Kept up to date and available at the jobsite
- Implemented under the supervision of a competent person
- A written explanation of why conventional fall protection is infeasible or more hazardous at each location
- Other measures to reduce or eliminate the fall hazard, such as using ladders, scaffolds or lifts
- Locations where conventional protection can’t be used, classified as controlled access zones
- A safety monitoring system where no other measure is used
- The names or identification of each worker allowed to work in controlled access zones
- Investigation of any fall or serious incident, and plan changes to prevent a repeat
Controlled access zones
A controlled access zone is an area where work can happen without conventional fall protection and access is limited to the named, authorized workers. It’s marked with control lines, generally set back from the edge, and everyone else stays out. See Warning Lines & Safety Monitoring.
Workers’ questions to ask
- Is there a written plan for this site, and have I seen it?
- Am I named as authorized to work in the controlled access zone?
- Who is the competent person and the safety monitor?
- Why can’t we use guardrails, nets or harnesses here?
Plans get misused. A generic plan copied from another job, or a plan used for work that isn’t leading edge, precast or residential, doesn’t meet the rule. New anchor products and equipment make conventional protection feasible in many situations that once seemed impossible.
Standards & references
- 29 CFR 1926.502(k): Fall protection plan
- Subpart M Appendix E: Sample fall protection plan
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