The Mechanical Contractors Association of America asked OSHA about service technicians who inspect and perform routine maintenance on rooftop air conditioning units located 15 or more feet from roof edges. The technicians do not conduct repairs — those require client approval and separate planning. The work occurs multiple times daily across different sites, with each visit lasting one to two hours. The question was whether 29 CFR 1910.28(b)(13)(iii)(A) applies to this work.
OSHA said yes, the standard applies. When work occurs 15 or more feet from roof edges, employers must provide fall protection through guardrail systems, safety nets, travel restraint systems, personal fall arrest systems, or designated areas — unless the work qualifies as both temporary AND infrequent.
The letter explains both terms. 'Temporary' means tasks that can be completed in less time than it would take to install conventional fall protection. 'Infrequent' means work performed only occasionally or sporadically — such as annual maintenance or equipment repairs — not daily or routine activities.
Applying those definitions, OSHA found the described work, though temporary, is not infrequent, because the technician faces fall hazards daily across multiple jobsites. Fall protection is therefore required for all such employees working 15 or more feet from roof edges, though OSHA noted employers may satisfy the requirement using designated areas for brief tasks.