New OSHA Fall Protection Focus Areas: What You Need to Know

By Jeremy Bonino – AVP, Risk Control March 04th, 2024

The Occupational Safety and Health Administration (OSHA) has recently emphasized the prevention of fall-related injuries and fatalities — which continue to pose a leading workplace risk, particularly in construction. During the February Captive Resources Risk Control Webinar, Roger Paveza, president of Vista Safety Consulting, explained OSHA’s new fall protection focus areas and how to address fall-related risks. Read on for a recap of Paveza’s presentation.

Fall Risks Increase as OSHA Enforcement Becomes Stricter

Paveza cited 2022 OSHA statistics to show that employers need to prioritize preventing fall-related and overall work-related injuries and fatalities:

  • Falls, Slips, and Trips (865) were the second most common type of work-related fatality category, behind only Transportation Incidents (2,066).
  • Fall-related risks pose a particular challenge in the construction industry, where falls are the leading cause of fatalities (38%).
  • Construction accounted for the vast majority of citations and inspections for OSHA’s Duty to Have Fall Protection standard at 97%.
  • Several fall-related OSHA standards for construction are currently among the most cited: Construction Fall Protection, Construction Scaffolding, and Construction Fall Protection Training.

With fall-related deaths and citations on the rise, the current U.S. regulatory environment is breeding stricter workplace safety enforcement, according to Paveza. In 2016, OSHA increased penalties by 78%. Since then, penalties have increased at about the same rate as the Consumer Price Index, and maximum penalties for “Serious” violations have jumped from $7,000 to $16,131 in 2024.

In 2017, OSHA revised the Walking-Working Surfaces rule for greater flexibility in using fall protection systems and added training and inspection requirements. Also, under the current administration, OSHA has made fall protection a National Emphasis Program.

Current OSHA Fall Protection Priorities

Paveza then provided several practical fall-related risk prevention priorities for employers that address OSHA’s new focus areas:

Fall Protection Height Requirements

Fall protection requirements for heights from lower levels are 4 feet or more for general industry, 6 feet or more for construction, and 10 feet or more for scaffolding.

Common Fall Hazards

Roofs, leading edges, window and wall openings, and floor holes are common fall hazards requiring fall protection.


Although guardrails are no longer mandated as a primary fall protection method under the revised Walking-Working Surfaces rule, they remain an easy fall protection measure when practical.

Personal Fall Arrest Systems

Employers must ensure that Personal Fall Arrest Systems (PFAS) fit properly, the Total Fall Distance is accurately calculated, and anchorages have sufficient weight capacity. Also, they should prepare a rescue plan for workers protected from a fall but unable to safely extract themselves from their PFAS.

Training Requirements

Employers must ensure that employees recognize the nature of fall hazards in work areas and know the correct procedures for setting up, maintaining, using, and inspecting fall protection and overhead protection systems.

How to Influence Productive Interactions with OSHA

Paveza offered several suggestions to ensure proper recordkeeping for site inspections and productive interactions with OSHA compliance and safety officers:

OSHA Inspection Plan

Ensure that employees know how to notify key company safety leaders. They should ask the OSHA officer to wait for the company compliance officer to arrive (typically, they will wait up to 60 minutes). Train employees to rightfully accompany an OSHA officer who will not wait for the company compliance officer to make the inspection.

Opening Conference

Employers should set up an opening conference with company representatives and use it to understand the purpose of the inspection and determine what the OSHA officer plans to inspect so they can formulate a logical site movement plan.

The Walk-Around

Take detailed notes of the inspection and duplicate any photos. Immediately correcting any potential issues that the OSHA officer raises will likely be perceived as a good-faith compliance effort. Ask the OSHA officer to make a formal document request if applicable.

Closing Conference

During the closing conference, the OSHA officer will report items that might be subject to citations, which must be issued within six months of a violation. This is the employer’s last chance to correct any misunderstandings.

Focus on Priorities for Favorable Outcomes

Paveza urged the audience to focus on a few priorities to achieve favorable outcomes in their efforts to comply with OSHA fall protection regulations:

  • Develop customized written safety programs.
  • Document site-specific training.
  • Focus on fall protection inspections and evaluations.
  • Instill employee discipline and accountability into fall protection practices.

About the Webinar

This presentation was part of Captive Resources’ Risk Control Webinar Series — regular installments of webinars to educate the group captive members we work with on topics like workplace safety, organizational leadership, and company performance. The thoughts and opinions expressed in these webinars are those of the presenters and do not necessarily reflect Captive Resources’ positions on any of the above topics.

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