Cal/OSHA Amends Residential Construction Fall Protection Standard

California OSHA (Cal/OSHA) has amended its fall protection standards in residential construction and roofing. The amendments include making the fall protection height standard 6 feet instead of 15 feet, making it more uniform to align with federal OSHA standards, and removing the term “impractical” and replacing it with “infeasible” within certain fall protection requirements. This term change will provide employers with more decision-making flexibility.

The new amendments were approved by the Office of Administrative Law (OAL) on Nov. 26, 2024, and go into effect on July 1, 2025.

Fall Protection Height Changes

Prior to the amendments, the height for triggering fall protection in residential roofing and construction was 15 feet. Now, fall protection for residential construction and roofing will be required at 6 feet instead of the 15 feet requirement.  

Employees must be protected from falling when on a roof surface where the employee fall distance is 6 feet or more above the grade or level below by use of one or more of the following methods:

• Personal fall protection systems;
• Scaffolding;
• Safety nets;
• Guardrails; or
• A fall protection plan with safety monitors and controlled access zones if the employer demonstrates that the use of conventional fall protection methods is infeasible.

In addition, these fall protection measures must be used for roof slopes 0:12 up to and including 7:12 and anything greater than a roof slope of 7:12. Previously, the range was 3:12 through 7:12 when employees must be protected from falling when on a roof surface where the eave height exceeded 15 feet above the grade or level below, and then anything over 7:12, a fall protection method was required.

Furthermore, for roofing work, employees’ fall height measurements must be determined by measuring the vertical distance from the employees’ walking/working surface to the ground level below. The height of parapets (any wall or railing that extends from the edge of the roof) is not included in the roof height measurement.

Change from “Impractical” to “Infeasible” for Fall Protection Plans

The fall protection plans section applies to all construction operations when it can be shown by the employer that the use of conventional fall protection is infeasible or creates a greater hazard. Prior to the amendments, this rule stated employers had to show that fall protection was impractical, meaning impossible. This change provides employers with more decision flexibility when considering cost and time. There is now a presumption that conventional fall protection is feasible and will not create a greater hazard.

The term “impractical” was changed to “infeasible” in the following sections:

• Fall protection plans;
• Work on top plate, joists and roof structure framing (1716.2(e)(1));
• Work on floors and other walking/working surfaces (1716.2(f));
• Work on starter board, roof sheathing and fascia board (1716.2(g)(1), (2)); and
• Fall protection for roofing work (1731(c)(1)).
• Accordingly, employers now have the burden of establishing that conventional fall protection is infeasible or creates a greater hazard. When conventional fall protection methods are found infeasible, employers must develop a site-specific fall protection plan that is created by a qualified person and supervised by a competent person. Safety monitors and controlled access zones may be used when traditional fall protection is not possible.

Employer Next Steps

These regulation changes will mostly affect residential construction and roofing contractors, roofers and framers. Employers must comply with the new requirements by July 1, 2025. Employers must update their fall protection plans, train employees on the changes and ensure that all their fall protection safety systems meet the new requirements.

Article Published By: Zywave, Inc.