Employee Login
2601 Market Place, Suite 200, Harrisburg, PA 17110   |   CALL US: 717.657.0909
SAFETY GUIDES THE PROCESS. ALWAYS.

Safety Talks

We are committed to construction safety. It is a commitment and the first core value that we have built into our culture.

Working Surfaces & Warning Line Utilization

Mar 10, 2025

Recent inspections and observed “Crane Lift” activity on roofs indicate that we need to refresh our understanding of the following:

  1. Knowledge related to working surfaces and utilization of warning line systems.
  2. The need to train others on the requirements for minimum working surface widths and their utilization of warning line systems.
  3. The need to enforce that NOBODY is working or accessing a work area on an inadequate working surface and secondly that nobody can work outside an established warning lines system without a PFAS or solid guard rail system.
  4. Need to assure that all access to working areas are a minimum of 18” wide.
  5. Need to review, plan and establish warning line systems for all current and future work to be compliant for the operational tasks at hand and for the specific trades preforming the work.

EXAMPLES OF INCIDENTS INVESTIGATED AND CITATIONS BY OSHA INCLUDE:

  1. OSHA Report – 8/2024: Falls from elevation are the leading cause of fatal and serious injuries among construction workers and rank among the most frequently cited safety violations by OSHA. In 2022, the Bureau of Labor Statistics reported 1,069 construction workers died on the job. Falls represent 36%, or 386 of all construction fatalities. Still, more than one construction worker a day falls to their death.
  2. OSHA Report – 10/14/2024 PLYMOUTH MA Darwin Chucuri Morocho (33) died in the fall through a stairwell opening.
  3. OSHA Report – 09/16/2024 Stafford KS, Kent Jost (60) died in fall from roof.
  4. OSHA Report – 08/2024 OSHA cited a company for allowing employees to work without protection at heights greater than six feet and for the unsafe.

REGULATIONS: WALKING WORKING SURFACES:

OSHA Standard Subpart L Scaffolds – 1926.451(b)(2)(i) Platforms and walkways shall be at least 18 inches (46 cm) wide.
OSHA Standard Subpart L Scaffolds – 1926.451 applies to platforms used solely as walkways or solely by employees performing work. All sections of each scaffold platform and walkway shall be at least 18 inches wide.
OSHA Standard Subpart P – Trenching – 1926.651(l) Walkways shall be provided where employees or equipment are required or permitted to cross over excavations. Guardrails that comply with 1926.502(b) shall be provided where walkways are 6 feet (1.8 m) or more above lower levels. OSHA Standard Subpart M Fall Protection – 1926.501(B)(2)(II) Each employee on a walking/working surface 6 feet (1.8 m) or more above a lower level where leading edges are under construction but who is not engaged in the leading edge work, shall be protected from falling by a guardrail system, safety net system or personal fall arrest system.

REGULATIONS: WARNING LINE SYSTEMS:

Standard Interpretations Use of a warning line instead of conventional fall protection; Part 1926 Subpart M January 3rd, 2005.

OSHA Standard Subpart M – Warning Line Systems General 1926.502(b) where all of the following are met: A warning line is used 15 feet or more from the edge (or nearest edge of a hole); The warning line meets or exceeds the requirements in 1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the hole or edge; and The employer effectively implements a work rule prohibiting the employees from going past the warning line; 1926.502(f)(1)(iii) Points of access, materials handling areas, storage areas, and hoisting areas shall be connected to the work area by an access path formed by two warning lines; 1926.502(f)(1)(iv) When the path to a point of access is not in use, a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line, shall be placed across the path at the point where the path intersects the warning line erected around the work area, or the path shall be offset such that a person cannot walk directly into the work area; 1926.502(f)(2) Warning lines shall consist of ropes, wires, or chains, and supporting stanchions erected as follows: 1926.502(f)(2)(i) The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with high-visibility material; 1926.502(f)(2)(ii) The rope, wire, or chain shall be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches (.9 m) from the walking/working surface and its highest point is no more than 39 inches (1.0 m) from the walking/working surface; 1926.502(f)(2)(iii) After being erected, with the rope, wire, or chain attached, stanchions shall be capable of resisting, without tipping over, a force of at least 16 pounds (71 N) applied horizontally against the stanchion, 30 inches (.8 m) above the walking/working surface, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge; 1926.502(f)(2)(iv) The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and after being attached to the stanchions, shall be capable of supporting, without breaking, the loads applied to the stanchions as prescribed in paragraph (f)(2)(iii) of this section; and 1926.502(f)(2)(v) The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over; 1926.502(f)(3) No employee shall be allowed in the area between a roof edge and a warning line unless the employee is performing roofing work in that area; 1926.502(f)(4) Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system.

OSHA Standard Subpart M – Low-Slope-Roof – Roofing Work – 1926.501(b)(10) Roofing work on Low-slope roofs. Except as otherwise provided in paragraph (b) of this section, each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system.

WHAT YOU NEED TO KNOW:

{A minimum of an 18” wide access plank or working area is required. A single plank access or working surfaces is NOT ADEQUATE.}

  • Across Trenches or for Work Area Access: Regardless of the height of the fall, walking surfaces or the access points to workings areas need to be a minimum of an 18” wide ramp. Please note that an 18” ramp or working surface may not be adequate if the fall hazard is greater than 6’. At that point, a handrail, fall restraint system, or personal fall arrest system (PFAS) is required.
  • Impalement Hazards: All impalement hazards need to be covered even if the walking/working surface is 18” and you are using a (PFAS).
  • On Scaffolding: One plank never provides enough working or walking surface width, even when using picks, they need to be at least 18” wide. The exception is for a pump jack system, which allows 12” in width. Again, note that a single plank is never acceptable for access or as a walking/working surface.
  • Warning Line Systems: Roofers area allowed 6’ for setback placement of their warning line systems. All other trades are required to set warning line systems at 15’. Hypothetically, if the roofer is responsible for setting up the warning line systems, they are compliant at 6’. All other trades on the roof are in violation and need a warning line system established 15’ from the leading edge of the roof.
  • Other Conditions: The “General Requirements” in 1926.502(b) for warning line systems are extremely specific. Please review the detailed specifications and construct or audit your site warning line systems to meet those guidelines.

 

“Fatality Inspection Data | Occupational Safety and Health Administration.” Www.osha.gov, www.osha.gov/fatalities#&sort.

“1926.451 – General Requirements. | Occupational Safety and Health Administration.” Osha.gov, 2019, www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.451.

‌“1926.651 – Specific Excavation Requirements. | Occupational Safety and Health Administration.” Osha.gov, 2019, www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.651.

‌OSHA. “1926.502 – Fall Protection Systems Criteria and Practices. | Occupational Safety and Health Administration.” Osha.gov, 2019, www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.502.

‌“Use of a Warning Line instead of Conventional Fall Protection; Part 1926 Subpart M | Occupational Safety and Health Administration.” Osha.gov, 2025, www.osha.gov/laws-regs/standardinterpretations/2005-01-03. Accessed 10 Mar. 2025.

‌OSHA. “Walking-Working Surfaces and Personal Fall Protection Systems Final Rule Frequently Asked Questions | Occupational Safety and Health Administration.” Www.osha.gov, www.osha.gov/walking-working-surfaces/faq.

 

Contact Us Today

Quandel Enterprises can help you achieve your commercial construction goals.

"*" indicates required fields

Hidden
Hidden
Hidden
Hidden
This field is for validation purposes and should be left unchanged.

Check Out More Articles

Read more of our informational articles below!