Effective July 1st, 2025, Cal/OSHA is implementing changes to construction fall protection standards for residential framing and roofing, lowering trigger heights from 15 feet to 6 feet. This brings Cal/OSHA’s regulations in line with the standard set by Federal OSHA.
Read the Fall Protection in Residential Construction Approved Text Here
Background
Historically, California maintained higher trigger heights for residential construction fall protection compared to federal standards, with requirements varying depending on the work being performed. This divergence led to ongoing discussions between Cal/OSHA and Federal OSHA, culminating in California’s decision to adopt the 6-foot trigger height to enhance worker safety and ensure consistency across jurisdictions.
Implications
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.
“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))
Additionally, employers now have the burden of showing 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.
Industry Compliance
The residential construction industry is preparing for these changes by investing in fall protection systems and training programs to ensure compliance. This update represents a significant step toward enhancing worker safety in California’s residential construction industry, reflecting a commitment to reducing fall-related incidents and aligning with national safety practices.
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