Helping to Keep Your Workers Safe with Fall Protection Systems and Equipment

The city of Memphis resides in the state of Tennessee and Tennessee has an approved OSHA State Plan called TOSHA. Regarding fall protection, TOSHA refers to OSHA CFR 2019 for all applicable fall protection requirements.

Along with TOSHA, the city of Memphis follows the International Building Code (IBC) along with some amendments. The amendments focus on a variety of things, but very few affect the standards surrounding fall protection.

Understanding Memphis Fall Protection Requirements

OSHA Standard Interpretation - Do I follow OSHA or local building code in Memphis?

The strictest rules must be followed. Where local codes are in effect, they are generally more specific and more stringent than applicable OSHA regulations. Compatibility with OSHA regulations is seldom an issue. (source)

OSHA 1910.5(c)(1) - What OSHA code applies in Memphis?

If a particular standard is specifically applicable to a condition, practice, means, method, operation, or process, it shall prevail over any different general standard which might otherwise be applicable to the same scenario. (source)

IBC 1013.2 - Where is guardrail required in Memphis?

Guards shall be located along open-sided walking surfaces, including mezzanines, equipment platforms, stairs, ramps, and landings that are located more that 30 inches measured vertically to the floor or grade below at any point within 36 inches horizontally to the edge of the open side. (source)

IBC 1013.2 - At what height do I need fall protection or guardrail in Memphis?

Guardrails are required on any elevated walking surface above 30 inches. (source)

OSHA 1910.29 - What can a guardrail be made out of in Memphis?

Guardrails, as long as they comply with all applicable standards, may be made out of any material. (source)

IBC 1013.3 - How tall does rooftop guardrail need to be in Memphis?

Guards cannot be less than 42 inches tall. (source)

OSHA 1926 Subpart M App B - How far apart can guardrail posts be in Memphis?

Guardrail posts may not be spaced more than eight feet apart. (source)

OSHA 1926.502(b)(2) - Do I need a mid-rail in Memphis?

Midrails must be installed between the top edge of the guardrail system and the walking/working surface when there is no wall or parapet wall at least 21 inches high. (source)

OSHA 1910.29(k) - When do I need a toeboard in Memphis?

Toeboards are required when there is danger of items falling from an elevated walking-working surface onto workers below. (source)

IBC 1607.8.1.1 - What are the load requirements for rooftop railing in Memphis?

Handrails and guards must be designed to resist a concentrated load of 200 pounds. (source)

OSHA 1910.29(b) - Can I use a non-penetrating guardrail in Memphis?

Yes, as long as it complies with all other guardrail standards. (source)

IBC 1012 - Can guardrail serve as handrail in Memphis?

Guardrails and handrails serve two different purposes and have different requirements. A handrail may be attached to a guardrail, but they are not one in the same. (source)

IBC 1013.2 - If my rooftop is lower than 22 feet but I have mechanical equipment close to the edge, do I need rooftop railing in Memphis?

Guards must be located along open-sided walking surfaces, including equipment platforms, that are located more that 30 inches measured vertically to the floor or grade below any point within 36 inches horizontally to the edge of the open side. (source)

IBC 1013.7 - If my rooftop is lower than 22 feet but I have a roof hatch close to the edge, do I need rooftop railing in Memphis?

If you have a roof hatch located within 10 feet of the roof edge, the roof access or roof edge must be protected by guardrail. (source)

OSHA 1926.501(b)(4)(i) - When is protection required when falling through a hole in Memphis?

Employees must be protected from falling through holes, including skylights, that have more than a 6 foot drop, by personal fall arrest systems, guardrails, or covers. (source)

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Michael Hannah
Fall Protection Specialist
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