Does "Subpart M - Fall Protection" Apply to You?
Subpart M provides the requirements for fall protection in construction workplaces. Note: The provisions of this subpart do not apply when employees are making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed.
The scope, application, and definitions applicable to this subpart sets forth those workplaces, conditions, operations, and circumstances for which fall protection shall be provided except:
- Fall protection requirements for employees working on scaffolds are provided in subpart L.
- Fall protection requirements for employees working on cranes and derricks are provided in subpart CC - fall protection.
- Fall protection requirements for employees performing steel erection work (except for towers and tanks) are provided in subpart R on steel erection on fall protection.
- Fall protection requirements for employees working on equipment used in tunneling operations are provided in subpart S - underground construction.
- Fall protection requirements for employees engaged in the erection of tanks and communication and broadcast towers are provided in subpart E - safety nets. Note: North Carolina has a state specific standard for communication towers that includes fall protection requirements.
- Fall protection requirements for employees working from aerial lifts or on poles, towers, or similar structures while engaged in the construction of electric transmission or distribution lines or equipment are provided in subpart V.
- Fall protection requirements for employees working on stairways and ladders are provided in subpart X - general requirements.
Personal fall arrest system means a system used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a body belt or body harness and may include a lanyard, deceleration device, lifeline, or suitable combinations of these.
Are your employees exposed to fall hazards that are not covered by another subpart as mentioned above? If yes, then you need to comply with subpart M.
The duty to have fall protection standard covers the general requirements for fall protection including walking and working surfaces having requisite strength and structural integrity to support employees safely. It also provides requirements for having fall protection (when six feet or more above lower level) for unprotected sides and edges, leading edges, hoist areas, holes, ramps, wall openings, and runways. It also provides requirements for fall protection during work operations involving excavations, formwork, dangerous equipment, overhand bricklaying and related work, steep roofs, precast concrete erection, residential construction and fall protection for walking and working surfaces (i.e., guardrail system, safety net system, personal fall arrest system). Further, it requires protection from falling objects (i.e., hardhat) along with other protective measures such as barricades, toeboards, screens, guardrail systems and canopy structures.
The fall protection systems criteria and practices standard provides fall protection system criteria for guardrail systems, safety net systems, personal fall arrest systems (PFAS), positioning device systems, warning line systems, controlled access zones, and safety monitoring systems. It also provides criteria for covering holes in floors, roofs, and other walking/working surfaces and protection from falling objects (i.e., toeboards, guardrails, canopies). Further, it provides an option for a fall protection plan that is available only to employees engaged in leading edge work [reference paragraph (b)(2)], precast concrete erection work [reference paragraph (b)(12)], or residential construction work [reference paragraph (b)(13)] who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment. The fall protection plan must conform to specific requirements including preparation by a qualified person, implemented by a competent person, and in writing.
Subpart M also provides the standard on training requirements which provides requirements for a training program, competent person to provide the training, certification of training (i.e., written certification record), and when retraining is required (i.e., inadequacies in an affected employee's knowledge or use of fall protection systems, changes in systems to be used).
The appendices for this subpart cover the following: appendix A pertains to determining roof widths; appendix B pertains to guardrail systems; appendix C pertains to personal fall arrest systems; appendix D pertains to positioning device systems and appendix E provides an example fall protection plan.
The NCDOL Library is available for assistance regarding access to consensus standards (i.e., ANSI, ASME, NFPA, IEEE). In addition, information can be found on the safety and health topics page for fall protection, competent person and personal protective equipment. Also reference SN 65 - The Use of Warning Lines Alone For Fall Protection on Low Sloped Roofs, SN 74 - Fall Protection Requirements for Work Involving Dry Laid Masonry Retaining Walls, STD 03-11-002 - Compliance Guidance for Fall Protection in Residential Construction, and OSHA Technical Manual (TED 01-00-015).