Fall Protection Training in Construction

29 CFR 1926.503 is the training section of OSHA's construction fall protection rules (subpart M). It asks three things of you as an employer: train each employee who might be exposed to fall hazards, keep a written certification of that training, and retrain when the earlier training no longer fits the job or the worker.

Who it applies to

Subpart M sets fall protection requirements for construction workplaces covered under 29 CFR part 1926 (1926.500(a)(1)). Within subpart M, section 1926.503 sets the requirements for training in the installation and use of fall protection systems (1926.500(a)(4)).

The training duty covers each employee who might be exposed to fall hazards (1926.503(a)(1)).

Main exclusions:

• Section 1926.503 does not cover training in relation to steel erection activities or the use of equipment covered by subpart CC (1926.500(a)(4)). That does not mean no training applies to that work: steel erection has its own fall hazard training paragraph (1926.761(b)), and so does equipment covered by subpart CC (1926.1423(k)).
• Subpart M does not apply when employees are making an inspection, investigation, or assessment of workplace conditions before the actual start of construction work or after all construction work has been completed (1926.500(a)(1)).

What the standard requires

Provide a training program

You must provide a training program for each employee who might be exposed to fall hazards (1926.503(a)(1)). The program must do two things (1926.503(a)(1)):

• Enable each employee to recognize the hazards of falling.
• Train each employee in the procedures to be followed in order to minimize these hazards.

Have a competent person do the training

You must assure that each employee has been trained, "as necessary," by a competent person qualified in the areas listed below (1926.503(a)(2)).

Part 1926 defines a competent person as one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them (1926.32(f)).

Cover the listed topics

The areas listed in the standard are:

• The nature of fall hazards in the work area (1926.503(a)(2)(i)).
• The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used (1926.503(a)(2)(ii)).
• The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used (1926.503(a)(2)(iii)).
• The role of each employee in the safety monitoring system when this system is used (1926.503(a)(2)(iv)).
• The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs (1926.503(a)(2)(v)). The paragraph says "low-sloped roofs"; the term subpart M defines is "low-slope roof," a roof having a slope less than or equal to 4 in 12, vertical to horizontal (1926.500(b)).
• The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection (1926.503(a)(2)(vi)).
• The role of employees in fall protection plans (1926.503(a)(2)(vii)).
• The standards contained in subpart M (1926.503(a)(2)(viii)).

Retrain when the training no longer holds

When you have reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (a), you must retrain each such employee (1926.503(c)).

The standard says retraining is required in situations that include, but are not limited to:

• Changes in the workplace render previous training obsolete (1926.503(c)(1)).
• Changes in the types of fall protection systems or equipment to be used render previous training obsolete (1926.503(c)(2)).
• Inadequacies in an affected employee's knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill (1926.503(c)(3)).

Written programs and records

You must verify compliance with the training requirements by preparing a written certification record (1926.503(b)(1)). The record must contain (1926.503(b)(1)):

• The name or other identity of the employee trained.
• The date(s) of the training.
• The signature of the person who conducted the training or the signature of the employer.

If you rely on training conducted by another employer, or completed prior to the effective date of the section, the certification record must indicate the date you determined the prior training was adequate rather than the date of actual training (1926.503(b)(1)).

The latest training certification must be maintained (1926.503(b)(2)).

A note at the end of the section says the appendices to subpart M serve as non-mandatory guidelines to assist employers in complying with subpart M (Note to 1926.503).

Easy-to-miss requirements

• "Might be exposed" is the trigger. The training program is for each employee who might be exposed to fall hazards (1926.503(a)(1)).
• The trainer has a stated qualification. Training is to be done by a competent person qualified in the listed areas (1926.503(a)(2)).
• Prior training needs your own date. When you rely on another employer's training, the record shows the date you determined that training was adequate, not the date the training took place (1926.503(b)(1)).
• The retraining list is not complete. The three listed situations are introduced with "include, but are not limited to." The underlying trigger is having reason to believe a trained employee does not have the required understanding and skill (1926.503(c)).
• The rules themselves are a training topic. The listed areas include the standards contained in subpart M (1926.503(a)(2)(viii)).

Related guides

• Fall protection
• Ladders
• Scaffolding

Source

This guide is based on the text of 29 CFR 1926.503 as published on osha.gov. The regulation itself always controls. States that run their own OSHA-approved State Plans may have additional or stricter rules.