OSHA Quiz – Does OSHA Require Fall Protection Around Trenches?

Scenario:  You are the safety manager for a fairly large general contractor.  You are doing a site audit of a project and you identify an open excavation greater than 6’ deep.  The site you are auditing has a perimeter fence for security with a guard at the gate.  At the time of the audit crews are working within close proximity of the excavation.

Question: Is fall protection required for the employees working adjacent to an excavation when the fall exposure is six feet or greater?

Answer: According to a federal OSHA Letter of Interpretation, fall protection would not be required as long as the excavation was visible.

“29 CFR 1926.501(b)(7) provides:

  • (i) Each employee at the edge of an excavation 6 feet (1.8m) or more in depth shall be protected from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barrier;
  • (ii) Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet (1.8m) or more in depth shall be protected from falling by guardrail systems, fences, barricades, or covers.

Under these provisions, if the trench is not readily visible because of plant growth or other visual barrier, fall protection is required. Thus, unless the trench you are describing is obscured from view, there is no requirement for fall protection to be provided.

The letter goes on to state that when fall protection is required around trenches, a controlled access zone is not an acceptable means of providing fall protection. Controlled access zones may only be used where employees are performing overhand bricklaying and related work; or as part of a fall protection plan for leading edge work, precast concrete erection or residential construction.

However, another question to ask may be “does it make sense to provide fall protection for employees working adjacent to, or walking close to the excavation?” Depending on the conditions, work activities and your company/client policies; yes, efforts should be made to protect employees from falling into the excavation.   Due diligence should be used in controlling hazards such as fall hazards.  With falls being one of the leading cause of injuries on a construction site, best management practices such as providing fall protection measures around an excavation could prevent this type of injuries from occurring.