Fall Protection Program: OSHA Requirements, Systems, and Written Plans (2026)

Falls kill more construction workers than anything else. In 2023, falls accounted for 39 percent of all construction fatalities, according to BLS data. The standard is not complicated. The compliance rate is not high. The gap between those two facts is where OSHA’s most-cited violation list comes from, year after year.

A fall protection program isn’t a binder in the office. It’s a documented system that tells your workers what protection is required, where, who’s responsible for it, and what happens when conditions change. Here’s what the standard actually requires and where programs typically break down.

Trigger Heights: Construction vs. General Industry

The rules differ depending on your industry, and getting them wrong means either over-engineering protection where it isn’t required or skipping it where it is.

For construction, 29 CFR 1926.502 sets the general trigger at 6 feet above a lower level. That covers most open-sided floors, floor holes, leading edges, and roofing work. But there are exceptions built into the standard. Workers near excavations need protection at 6 feet from the edge. Workers above dangerous equipment, like exposed rotating machinery or impalement hazards, need protection regardless of height. Hoist areas require protection at 6 feet. Formwork and reinforcing steel work has its own section.

General industry operates under 29 CFR 1910.28, and the trigger is 4 feet for most walking-working surfaces. It drops to 12 feet for work on vehicles and mobile equipment, and to 10 feet for fixed ladders. Scaffolding has its own separate rule. The 4-foot threshold catches a lot of employers by surprise, particularly in warehousing and manufacturing where mezzanines and loading docks are common.

The practical takeaway: never assume the trigger height. Look up the specific activity in the applicable standard before writing your fall protection plan.

The Competent Person Requirement

OSHA uses two defined terms in fall protection: competent person and qualified person. They’re not the same, and mixing them up creates real compliance problems.

A competent person can identify existing and predictable hazards and has the authority to take prompt corrective action. For fall protection, they need to be able to recognize fall hazards, inspect equipment, and actually stop work when a hazard exists. The authority piece matters. A competent person who can identify a problem but needs to get three levels of management approval before anything gets fixed isn’t functioning as a competent person.

A qualified person has a degree, certificate, or professional standing in a relevant field, or extensive knowledge, training, and experience, such that they can solve problems in that field. Designing a personal fall arrest system for a specific anchor configuration, for example, requires a qualified person. Inspecting a harness before use requires a competent person.

Your fall protection program must designate a competent person by name or job title. That designation needs to be documented. Training records need to show the designated person actually received training on fall protection. Most citations for this violation come from companies that named someone as competent person but can’t produce any documentation that the person was trained or that they have real authority.

Choosing the Right Fall Protection System

OSHA gives employers three primary options for fall protection: guardrail systems, personal fall arrest systems (PFAS), and safety nets. The standard allows employers to choose among them in most situations. But “allowed to choose” doesn’t mean the choice is unlimited.

Guardrail systems are passive protection. Workers don’t need to wear anything or do anything different. That makes guardrails the preferred system when work is stationary and the area can be defined. The standard sets top rail height at 42 inches, plus or minus 3 inches, with a mid-rail required. Guardrails must withstand 200 pounds of force applied outward or downward at any point.

Personal fall arrest systems stop a worker who has already fallen. They require a harness, a connector (lanyard or self-retracting lifeline), and an anchor. The key word is “arrest.” A PFAS doesn’t prevent a fall. It catches the worker after the fall starts. That distinction matters for system selection. If there isn’t enough clearance below the worker for a free fall, a deceleration distance, and a safety margin, a PFAS can’t be used without risking contact with a lower level even when the system functions perfectly.

Safety nets are common on large construction projects where overhead work creates fall hazards below. They catch falling workers and debris. They’re expensive to install and maintain, which is why you don’t see them on most residential and small commercial sites.

For most small contractors, the decision comes down to guardrails vs. PFAS. Use guardrails where you can. Use PFAS where guardrails aren’t feasible. Document the decision either way.

Personal Fall Arrest System Components

Every PFAS has three components: the body harness, the connector, and the anchorage. All three must meet OSHA requirements and work together as a system.

The harness must be a full-body harness. Belts are no longer acceptable for fall arrest. The harness must fit properly, meaning the leg straps, chest strap, and shoulder straps are all adjusted so the D-ring sits at shoulder blade level or above. A low D-ring means a longer fall distance before the system becomes taut.

The connector connects the harness to the anchor. Two types are common. Shock-absorbing lanyards deploy a rip-stitch deceleration element on arrest, spreading the impact over time. They add about 3.5 feet to the fall distance when deployed, which has to be accounted for in clearance calculations. Self-retracting lifelines (SRLs) lock almost immediately during a fall, limiting free fall to inches rather than feet. SRLs are generally the better choice when clearance is limited or when workers are moving around.

Anchor point requirements are strict: 5,000 pounds per attached worker, or designed by a qualified person as part of a complete system with a safety factor of at least two. Structural steel beams often meet this. Rebar, pipes, and random structural members often don’t. Every anchor selection needs to be evaluated before use, not assumed.

The Written Fall Protection Plan

Most employers confuse a written fall protection plan with a fall protection program. They’re different.

A fall protection program is your overall system: what protection is required, the equipment standards, the competent person designation, training requirements, and inspection procedures. Every employer required to have fall protection should have a fall protection program.

A written fall protection plan under 29 CFR 1926.502(k) is a specific document required when conventional fall protection is infeasible or would create a greater hazard. It’s not an alternative to a fall protection program. It’s an exception document for specific situations where guardrails, PFAS, or nets can’t be used.

The written plan must document the reason conventional protection can’t be used, the alternative measures being taken, the identity of the qualified person who developed the plan, and the specific location and tasks it covers. It must be site-specific and task-specific. “Roofing work is dangerous” is not a justification. “Installing metal deck on a 28-degree slope where guardrails would require penetrations that compromise the waterproofing membrane” is the kind of documented engineering reason the standard contemplates.

Keep a copy on the jobsite. Update it when conditions or tasks change.

Equipment Inspections

OSHA requires harnesses, lanyards, and SRLs to be inspected before each use. That’s a pre-use check: look for cuts, abrasions, fraying, broken stitching, deformed or corroded hardware, chemical contamination, and heat damage. Run your hands along the webbing to feel for damage that’s not visible. Check that snaps and carabiners lock and unlock correctly.

Beyond pre-use inspection, a competent or qualified person must conduct more formal inspections at intervals appropriate to the work environment. Most programs do this annually. Harnesses used in environments with chemical exposure, UV exposure, or heavy daily use may need more frequent formal inspection.

Any equipment that has arrested a fall is done. Take it out of service immediately. Even if nothing is visibly wrong, the internal components may have been stressed past their safe limit.

Training Requirements

1926.503 requires training before workers use fall protection or work in areas where fall hazards exist. The training must cover the nature of fall hazards in the work area, the correct procedures for erecting, maintaining, disassembling, and inspecting fall protection systems, the use and operation of the specific systems the worker will use, the role of each employee in the fall protection plan, and the limitations of fall protection systems.

Training must be conducted by a competent person. It must be done in a language and vocabulary the worker can understand. You need documentation: who was trained, when, by whom, and what was covered.

Retraining is required any time you have reason to believe a worker doesn’t understand the training, a change in the workplace makes previous training obsolete, or new fall protection equipment or methods are introduced.

Common Fall Protection Violations

The same violations appear on OSHA’s most-cited list every year because the problems are predictable. No fall protection where it’s required is the most cited, and it almost always involves residential construction framing crews or roofing contractors who assume their risk tolerance counts as a compliance strategy.

Unqualified competent person designations are a close second. The fix isn’t naming the right person. It’s documenting that the person was actually trained, tested for understanding, and has real authority.

Anchor point problems are where technically compliant programs often fail. Workers tie off to whatever is available: rebar, pipes, scaffold frame members. Some of those work. Many don’t. A competent person needs to pre-authorize specific anchor points for each task.

Anchor points are where most small-contractor fall protection programs actually break down. The harness gets worn, the lanyard gets clipped on, but the anchor point is whatever was convenient. A valid fall protection program specifies approved anchorages in advance, not after a worker has already decided where to clip in.