6.1 MIOSHA Part 45 Fall Protection & Personal Fall Arrest Systems
Key Takeaways
MIOSHA Part 45 adopts 29 CFR 1926.500 to 1926.503 by reference, so federal Subpart M rules are Michigan's fall protection rules for construction.
Workers in residential construction and on steep roofs (slope greater than 4:12) must be protected at 6 feet or more by guardrails, safety nets, or personal fall arrest systems.
Personal fall arrest anchorages must hold 5,000 pounds per attached worker, or be designed with a safety factor of at least 2 under a qualified person.
A harness system must limit arresting force to 1,800 pounds, free fall to 6 feet, and deceleration distance to 3.5 feet, and only locking snaphooks may be used.
Equipment that has arrested a fall must be removed from service until a competent person inspects it and finds it undamaged, and the employer must provide for prompt rescue.
Michigan's Fall Protection Rule
Michigan runs its own OSHA-approved state plan, MIOSHA, under 1974 PA 154. For construction fall protection, Part 45 (R 408.44501–44502, amended April 2015) adopts by reference 29 CFR 1926.500, .501, .502, and .503, known as federal Subpart M. Part 45 also points to other MIOSHA parts for special situations: ladders in Part 11, scaffolds in Part 12, and aerial work platforms in Part 32 (Section 6.3).
Key definitions from 1926.500:
- Low-slope roof: slope less than or equal to 4 in 12.
- Steep roof: slope greater than 4 in 12.
- Competent person: someone able to identify hazards who has authority to correct them promptly.
- Qualified person: someone with a degree, certificate, or extensive experience who can solve problems related to the subject.
Who Must Be Protected (1926.501)
| Situation | Trigger | Acceptable protection |
|---|---|---|
| Residential construction (b)(13) | 6 feet or more above a lower level | Guardrails, safety nets, or personal fall arrest. A written site-specific fall protection plan only if the employer shows those are infeasible or create a greater hazard |
| Steep roofs (b)(11) | 6 feet or more | Guardrails with toeboards, safety nets, or personal fall arrest |
| Low-slope roofing work (b)(10) | 6 feet or more | Guardrails, nets, personal fall arrest, or a warning line combined with one of those or with a safety monitor. On roofs 50 feet or less wide, a safety monitor alone (Section 6.2) |
| Holes, including skylights (b)(4) | More than 6 feet | Personal fall arrest, covers, or guardrails around the hole (Section 6.2) |
Subpart M presumes that at least one conventional system is feasible for residential work. A fall protection plan is the exception, not the default.
Personal Fall Arrest Systems (1926.502(d))
A personal fall arrest system combines three parts: an anchorage, a full-body harness, and a connector (lanyard, self-retracting lifeline, or rope grab on a lifeline).
| Requirement | Rule |
|---|---|
| Anchorage strength | Holds 5,000 pounds per attached employee, or is designed, installed, and used as part of a complete system with a safety factor of at least 2, under a qualified person ((d)(15)) |
| Maximum arresting force | 1,800 pounds with a body harness ((d)(16)(ii)) |
| Free fall | Rigged so the worker can neither free fall more than 6 feet nor contact any lower level ((d)(16)(iii)) |
| Deceleration distance | Worker stopped within 3.5 feet of deceleration ((d)(16)(iv)) |
| Snaphooks | Locking type only since January 1, 1998. Not clipped to each other, to webbing, or to a D-ring already holding another connector unless designed for it ((d)(5)–(6)) |
| Body belts | Prohibited for fall arrest since January 1, 1998. A full-body harness is required |
| Vertical lifelines | One employee per lifeline, and lanyards and lifelines rated at 5,000 pounds ((d)(9)–(10)) |
| Attachment | Not tied to guardrail systems or to hoists ((d)(23)) |
Roof Anchors
Install roof anchors exactly as the manufacturer instructs. Most require fastening through the sheathing into rafters or truss top chords with specified fasteners, not just into the deck. Place the anchor as nearly above or up-slope of the work as possible to limit swing falls, where a worker offset from the anchor swings sideways into walls or off a rake.
Inspection, Impact, and Rescue
- Inspect the system before each use for wear, damage, and deterioration, and remove defective parts from service ((d)(21)). Check webbing for cuts, burns from torches or hot asphalt, and chemical damage. Check hardware for cracks and distortion, and check impact indicators.
- Equipment that arrests a fall, or is otherwise impact loaded, must be removed from service immediately and not reused until a competent person inspects it and finds it undamaged and suitable ((d)(19)). Many manufacturers require retiring impact-loaded lanyards and self-retracting lifelines, so follow their instructions.
- The employer must provide for prompt rescue of a fallen worker or make sure workers can rescue themselves ((d)(20)). Suspension in a harness quickly becomes a medical emergency, so plan the rescue before work starts.
Training and Certification (1926.503)
- Each employee exposed to fall hazards must be trained by a competent person to recognize hazards and use the systems.
- The employer keeps a written certification record with the employee's name, the training dates, and the signature of the trainer or employer.
- Retrain when the workplace, the equipment, or the worker's performance shows the training is out of date.
MIOSHA publishes a Part 45 quick guide and a sample fall protection plan for residential construction. The sample is useful for seeing what a site-specific plan must contain. It does not replace conventional protection when conventional protection is feasible.
Estimating Fall Clearance
A lanyard that stops a fall after the worker hits the ground is useless. Clearance below the anchor depends on the equipment. Manufacturers publish clearance charts, and a typical estimate for a 6-foot shock-absorbing lanyard attached at back level adds these items:
| Component | Typical value |
|---|---|
| Lanyard length (free fall) | 6.0 ft |
| Deceleration distance (maximum) | 3.5 ft |
| D-ring to feet, including harness stretch | About 5.0 ft |
| Safety margin | Commonly 2 to 3 ft |
| Total below the anchor | About 16.5 to 17.5 ft |
On a single-story ranch with an 8-foot eave, a 6-foot shock-absorbing lanyard at deck level cannot keep a falling worker off the ground. Use a self-retracting lifeline rated for the setup (leading-edge rated if anchored at foot level), a rope grab on a ridge-anchored lifeline kept short, guardrails, or roof brackets with guardrails.
Worked Scenario
A crew reroofs a two-story colonial with a 9:12 roof and eaves 18 feet above grade. The roof is steep, and the work is more than 6 feet up, so the crew needs guardrails with toeboards, nets, or personal fall arrest. The foreman installs two anchors near the ridge into rafters, following the manufacturer's instructions. Each worker has a full-body harness and a rope grab on a separate vertical lifeline, kept adjusted to limit slack. Every harness is inspected at the start of the shift, and a ladder and trained coworker are available for rescue.
Under MIOSHA Part 45, what must a non-engineered anchorage for a personal fall arrest system be able to support?
1,800 pounds per attached worker
3,000 pounds per attached worker
5,000 pounds per attached worker
Twice the worker's body weight
A worker's shock-absorbing lanyard deploys when he slips off an eave. What must happen to the lanyard and harness?
Remove them from service immediately and do not reuse them until a competent person inspects them and finds them undamaged and suitable
Return them to service after the worker visually checks the webbing
Keep using them for the rest of the shift and replace them at the end of the week
Reuse them if the impact indicator can be reset
Which fall protection option is acceptable for a crew shingling a 7:12 residential roof with eaves 12 feet above the ground?
A safety monitor alone, because the house is only one story
A warning line 6 feet from the eave
No protection, because fall protection starts at 15 feet on residential work
Guardrails with toeboards, safety nets, or personal fall arrest systems
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