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

The city of San Juan resides in Puerto Rico and Puerto Rico has an approved OSHA State Plan called PROSHA. Regarding fall protection, PROSHA refers to OSHA CFR 2019 for all applicable fall protection requirements.

Along with PROSHA, the city of San Juan follows the Puerto Rico Building Code (PRBC). PRBC adheres to the International Building Code standards, but applies amendments that are relevant to the US territory.

Understanding San Juan Fall Protection Requirements

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

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 San Juan?

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)

PRBC 1015.2 - Where is guardrail required in San Juan?

Guards shall be located along open-sided walking surfaces, including mezzanines, equipment platforms, aisles, 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)

PRBC 1015.2 - At what height do I need fall protection or guardrail in San Juan?

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

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

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

PRBC 1015.3 - How tall does rooftop guardrail need to be in San Juan?

Guards must be 42 inches tall, give or take 3 inches. (source)

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

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

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

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 San Juan?

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

PRBC 1607.8.1.1 - What are the load requirements for rooftop railing in San Juan?

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 San Juan?

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

PRBC 1014 - Can guardrail serve as handrail in San Juan?

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)

PRBC 1015.2 - If my rooftop is lower than 22 feet but I have mechanical equipment close to the edge, do I need rooftop railing in San Juan?

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)

PRBC 1015.7 - If my rooftop is lower than 22 feet but I have a roof hatch close to the edge, do I need rooftop railing in San Juan?

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 San Juan?

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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