Q. Your May 2001 article "Fall Protection Update" says that OSHA Standard 29 CFR 1926 requires fall protection for anyone working above 6 feet. Here in Washington state, I understand that the standard applies when there is a 10-foot fall potential. What accounts for the discrepancy?

A.Steve Cant, federal-state operations manager at the Washington Department of Labor and Industries, responds: You are correct that the fall protection standard used in Washington differs from the OSHA standard. The State of Washington, like 26 other states and territories, is authorized by OSHA to operate a state plan for occupational safety and health. In fact, Washington had a state-operated program long before Congress passed the OSHA legislation. State plans are required to be as effective as any applicable OSHA standards, although they are not required to be identical.

Unlike the OSHA standard, Washington’s fall protection standard relies on a "firm 10-foot" rule applied throughout the construction industry. The federal OSHA standard includes a range of requirements, depending on the type of construction activity involved; it even allows employers to declare that fall protection is not readily feasible in cases where the State of Washington requires it to be implemented. Washington has enforced the 10-foot fall protection requirement in residential construction for more than ten years. In combination with requirements for walking-working surfaces at 4 feet, and special precautions above 6 feet, the consistent requirement for using fall restraint devices above 10 feet has proven to be an easily understood and applied alternative to OSHA’s standard.