When are fall protection anchors required?

Buildings 3 stories or 36’ or more from top of parapet.

California Code of Regulations Title 8 Section 3291. Special Design Considerations—Permanent Roof

  1. Roof Tie-Backs.
  • Every building constructed 3 stories or 36 feet or more in height, shall have roof tie-backs or other permanent devices installed at the roof level for the purpose of securing or tying back suspended scaffold hooks or clamps and safety lines.


  1. Roof tie-backs are not required on buildings employing other acceptable means of permanently installed roof top maintenance systems specified in this Article or Article 6.
  2. Roof tie-backs are not required on buildings constructed up to 4 stories or 48 feet in height when building maintenance can be accomplished using extension tools, ladders, approved ground equipment such as scaffolds, or aerial devices designed and used for positioning personnel.


Are fall protection anchors required on buildings lees than 36’?


  • Where there is a routine need for workers to approach within 6 feet of a fall hazard, fall protection must be provided for the worker.
  • Routine is defined as four or more times per year; a fall hazard is defined as an elevation difference of 30” or more.
  • A 42” or higher parapet or guard rail is a passive fall protection system and meets the fall protection requirements.
  • If the parapet or railing is not 42” in height a routine maintenance fall protection system must be designed.


What is the spacing for fall protection anchors?

  • Such devices should be spaced at approximately 12-foot intervals; however, the spacing shall depend primarily on the availability of roof structural framing members of sufficient strength to safely carry applied loads. Tie-backs may be installed in structural parapets that are of adequate strength to sustain applied loads, but, placement shall be as close to the roof level as practicable. Design criteria for tiebacks shall be as follows:


Are exterior building maintenance designs required?

It depends:

Are the windows going to be washed?

If Yes, that is considered scheduled maintenance. 

  • Widow washing companies are required to follow an Operating Procedure Outline Sheet (OPUS) which requires an EBM design. Window washing companies can be fined if an OPUS is not provided.
  • An EBM system plan must be designed by a by a Scaffold, Inspection and Testing (SIT) company.
    • An EBM design and OPOS is not required to obtain the building permit but is required prior to scheduled maintenance (window washing).

If No, scheduled maintenance does not need to be considered however tie backs are still required.

  • Tie Backs must be placed at approximately 12’ o.c.
  • There is no requirement that the tie back layout be laid out by a SIT however, some project specifications may require a SIT for layout.

The owner must consider if the building will require unscheduled maintenance. (Paint and Repairs)

Painting and repair contractors will be required to follow an OPUS.  An OPUS may be obtained later but there is a risk that the fall protection system may have to be altered which could require additional cost.  This cost could be significant.


Are Fall Protection Anchor required to be installed by EBM companies?


  • Unless specified in the project specification (very rare) the contractor can install the fall protection anchors.
  • It is very common that the framer on the project installs the fall protection anchors.
  • Hardy Fall protection Systems recommends that the framer installs the Hardy Saddle on the ground prior to installing the beams or trusses. It is much safer and faster. (see our video on the home page)


Is load testing required?


California Code of Regulations Title 8 Section 3296

  1. All completed building maintenance equipment installations shall be inspected and tested in the field before being placed in initial service to determine that all parts of the installation conform to applicable requirements of this article, and that all safety and operating equipment is functioning as required.
  2. (4)(B) Roof tie-backs shall be tested to no more than 50 percent of their rated capacity. For example, a roof tie-back with a rated capacity of 5000 pounds shall not be tested in excess of 2500 pounds.

Hardy Fall Protection Systems, Inc. includes load testing.  Testing is provided by an independent testing agency.  Specialized Testing – www.specializedtesting.com


Can fall protection anchors be eliminated if operable windows are installed?


California Code of Regulations – Title 8 Section 3282

2)   (g) (1) In every building where window cleaning operations are performed in such a manner that a person stands on the sill in order to clean the window or works from the inside where the window opening is of such size that it would be possible to fall through the open window to the outside, there shall be installed window cleaning safety anchors or other anchorages approved by the Division. (Title 24, Part 2, Section 2-8502(a).)

3)   (2) Any window which when fully opened has a clear opening with the lesser dimension exceeding 18 inches, or any window in which the height to width relationship presents a hazard, shall be considered as presenting the hazard of falling through as specified in Section 3282(g)(1) above. (Title 24, Part 2, Section 2-8502(a)2.)

4)   (3) In every building other than those described in Section 3282(g)(1), provisions shall be made for window cleaning by use of elevating platforms, rolling scaffolds, suspended scaffolds, boatswain’s chairs, or ladders, as specified in these orders. (Title 24, Part 2, Section 2-8502(a)1.)