 There are many changes that will be acceptable for compliance with the residential construction standards during the rulemaking period. We would like to review them with you. In the existing standard, the intended use of the building dictated when a structure was considered residential, allowing the option of a fall protection plan. Under the new guidelines, the construction methods and materials dictate whether or not a work site can be considered residential construction. A site-specific written fall protection plan is required in the existing standard when conventional fall protection is infeasible or creates a greater hazard. The new policy allows the contractor the option of no written plan if the sample protection plan in the appendix of the existing standard is followed when working on these four areas. Setting and bracing trusses or rafters. Erecting exterior walls. Setting floor joists and sheathing. And installing roof sheathing. The no written plan option is also an alternative when working on tops of foundation walls, roofs, performing tasks other than roofing work. For example, installing gutters, antennas and vents. Working on attics such as wiring, ventilation and insulation work. This option can only be used in these seven areas if the contractor adheres to the following safety measures. Only trained workers are allowed to do the work. All form work needs to be adequately supported. Work is suspended in adverse weather. Materials and equipment are conveniently located. Areas below workers must be kept free of hazards. Workers not involved in operations need to stay clear of areas below or adjacent to any openings. The new directive also defines alternatives for compliance with steep roof work. Low slope roofs are not affected. When we refer to roofing work, we are addressing activities involving the installation or removal of the waterproofing layer on a roof deck. In the existing standard, conventional fall protection is required on steep roofs whenever the fall distance is six feet or greater and the slope is four in twelve or steeper. The interim guidelines offer a slide guard option on steep roofs where the fall distance is 25 feet or less and the slope eight in 12 or less. The slope of the roof dictates the type and number of slide guards necessary. On roofs with slopes less than or equal to six in 12, a continuous slide guard must be installed along the entire eve at an angle of approximately 90 to the slope of the roof. On roofs with slopes between six in 12 and up to and including eight in 12, a continuous eve slide guard is necessary plus the use of additional slide guards installed no more than eight feet below a roofer at all times. It is not necessary for these additional slide guards to extend the full length of the roof. They may be placed only under the working area. However, it is important that they are no further than eight feet below the worker. If the slide guard option is selected by a contractor, the following safety measures must be followed. Only trained workers are allowed on the roof. Roof surfaces must be free of any potential slipping hazards. Workers must wear appropriate footwear. Work must be suspended in adverse weather. Holes or damaged portions of the roof surface must be repaired covered or surrounded by guardrails. Workers must not ascend or descend the roof slope within six feet of the rake edge. Supplies should not be stored within six feet of the rake edge. Areas below the eaves and rakes must be kept clear and free of hazards. The slide guard brackets may not be appropriate with certain roofing materials such as metal and tile. Therefore, on those roofs, the new directive allows the use of a safety monitoring system in place at the slide guard option. Conventional fall protection is still the only acceptable choice when working on roofs with slopes greater than 8 in 12 and on steep roofs where the eave to lower level fall distance is more than 25 feet. The slide guard option in these cases does not apply. If you don't mind, I'd like to go over the new regulations. I want to make sure that this is clear and that I understand them correctly. Help me remember how we define residential construction under the new interim guidelines. Jim, it's the construction methods and material that are used in determining the term residential now, not the intended use of the building like before. OK, now it's my understanding that contractors can utilize the no written plan option in seven areas of construction. Can you remember those seven areas? That's correct, Jim. When employees are erecting exterior walls, when employees are setting, embracing trusses or rafters, also when employees are setting, embracing floor joist and sheathing, as well as roof sheathing, where workers are required to work on roofs to install gutters and antennas, where workers must work on the tops of foundation walls and where employees must work in attics to install electrical wiring, ventilation and insulation. OK, well, that's pretty easy to remember. I guess as compliance officers, it's important for us to remember that the contractor as well as us should remember they have to implement certain safety measures in order to protect those employees. What are those areas? Employees that are involved in the operation must be trained on how to do the work. Also, materials must be conveniently located in the work area. Workers not involved with the operation must stay clear below or adjacent to openings. Also, work must stop in climate weather. Well, Joe, that was pretty good. Now I've got a slide guard question for you. It's my understanding, according to the new directive, that during steep slope roofing operations, 8 and 12 and less with a fall distance from ground to eave height, 25 feet or less, a roofer now has the option of installing what's called a slide guard. That's right, Jim. And the key thing to remember is that it is the slope that dictates the type and number of slide guards required for the roofing operation. OK, now let's see if I remember. Steep slope roofing operations with slopes 6 and 12 or less with a ground to eave height of 25 feet or less, the roofer now has the option of installing the slide guard, providing it runs the entire length of the eave. Correct. So those roofing operations from 6 and 12 slopes, up to and including 8 and 12 slopes, must install a slide guard not only the entire length of the eave, but he must install an additional slide guard within 8 feet of the worker. That's correct. But it doesn't have to go the entire length of the eave. That's right, Jim. What's your question? My question is, what about houses that have different elevations from the front and the back of the house? That's a good question, Jim. Houses that are built on sloping ground or where they're built on sloping ground, if the eave height in the front of the house is 20 feet and the eave height in the back of the house is 30 feet, then the slide guard option would only apply to the front, would not apply to the back. OK, I think I understand. Now I've got another one for you. What applies when the slope of the ground parallels the eave? The same thing applies. Where the fall distance is 25 feet or less, the slide guard option can be used. Anything greater than 25 feet, the slide guard option does not apply. One other thing, too, Jim, I would want to point out is that the rake edge or the gable edge of the roof has no bearing on whether or not a slide guard option can be used. It is only the eave height that is used to determine the slide guard option. I understand. Also, Jim, I'd like to point out that failure to provide fall protection in compliance with the new safety directive could be subject to citation because it will be in violation with 1926.501. This directive, which is a product of the partnership between OSHA and the residential construction industry, will result in a more uniform application, a fall protection requirements nationwide. It will also result in increased voluntary compliance. OSHA is confident that with the new awareness and the fall protection hazards in residential construction, there will be a significant increase in participation in the forthcoming rulemaking. This can only result in a rule that is more responsive to the industry and better address those work practices and materials inherent to residential construction.