An HVAC service company described a technician using a portable ladder to access a low slope roof 12 feet high. The ladder was secured to the building at a 4-to-1 angle with side rails extending three feet above the roof landing, and the HVAC unit needing work was 25 feet from the roof edge. The company asked whether fall protection was required when the employee stepped from the ladder onto the roof and walked to the unit, and whether guardrails had to be installed at the ladder landing.
On the first question, OSHA said no — it has no specific standards requiring fall protection when an employee steps off a portable ladder onto a low slope roof and walks directly from the ladder to a work area 25 feet from the edge. But OSHA added an important qualifier: when work occurs 15 or more feet from the roof edge and the work is not both infrequent and temporary, employers must provide fall protection under 29 CFR 1910.28(b)(13)(iii).
On the second question, OSHA again said no — there are no specific requirements for guardrails on the landing surface where an employee exits a ladder. However, under 29 CFR 1910.28(b)(13)(i), when work is performed less than 6 feet from the roof edge, the employer must protect employees with a guardrail system, safety net system, travel restraint system, or personal fall arrest system.
The letter also noted that North Carolina, where the inquirer was located, operates a state plan that may impose stricter requirements than federal OSHA standards.