The 6 ft edge trigger
Under 29 CFR 1926.501(b)(1), a worker at an unprotected side or edge that is 6 ft (1.8 m) or more above a lower level must be protected by one of three conventional systems: guardrail systems, safety net systems or personal fall arrest systems.
Residential construction is not exempt. 1926.501(b)(13) gives residential work the same 6 ft trigger.
Numbers that are not the edge trigger
- 10 ft is the scaffold trigger (more than 10 ft, under 1926.451).
- 4 ft is the general-industry number.
- 5 ft is the excavation depth at which a cave-in protective system is required.
- 15 ft does not appear in the rule at all.
Trap: the 6 ft trigger is for edges; scaffolds use more than 10 ft.
Working the scenario
A framer stands at the unprotected edge of a second-floor deck 8 ft above the ground, not on a scaffold or a ladder. 8 ft is at least 6 ft, so guardrails, nets or personal fall arrest are required. Residential work changes nothing, and 10 ft and 15 ft are not the edge trigger.
The written fall protection plan is an exception
1926.501(b)(13) lets a residential employer use a written fall protection plan meeting 29 CFR 1926.502(k) instead of the conventional systems, but only when the employer can demonstrate that guardrail, safety net and personal fall arrest systems are infeasible or create a greater hazard.
Traps:
- The plan is not a free alternative the employer may pick whenever it prefers.
- Edge height does not qualify a plan. There is no rule that edges under 10 ft may use one; 10 ft is the scaffold trigger.
- How long the task lasts, such as work finishing in under a day, is not the test. Infeasibility or greater hazard is.