Simplifying your toolbox talks

What you need to know

Workers need to be protected from falling through holes, including skylights, on walking and working surfaces 6 feet above lower levels. Protection methods can include: covers, fall arrest systems, or a guardrail system erected around such openings.

Plywood hole cover marked with the words “Hole, No Load”

Covers should:

  • Support at least twice the maximum expected weight of workers, equipment, and materials.
  • Be configured to protect employees from tripping or stepping into or through holes.
  • Protect employees from objects falling through holes.
  • Be secured so they will not be displaced.
  • Be large enough to provide appropriate overlap to prevent workers from fall through and have a full-edge bearing on all four sides.
  • Be painted with a distinctive color and marked with the word “HOLE” or “COVER.”
  • Be left in place over the hole until access is needed and also be inspected regularly.

Note: Information on plywood covers can be referenced at 29 CFR 1926.501(b)(4) and 29 CFR 1926.501(i)(1), (i)(2).

Additional Actions:

  • Never sit on or lean against an unprotected skylight.
  • If you see an unprotected hole or skylight, notify the competent person or jobsite superintendent.
  • If you create or uncover a hole, guard it with an approved guardrail or protect it using the hole cover guidance above.
  • If workers are unable to protect or guard holes or skylights, they must be protected from falls with an approved personal fall arrest system or fall restraint system.

Note: Skylights are not considered covers or protected unless they are manufactured to meet OSHA/ANSI strength requirements or retrofitted with guards that meet those requirements. Skylights should be considered unprotected openings unless the competent person inspects and verifies the manufacturer specifications on strength ratings and/or listings.

Why it matters

Falls hazards of holes or skylights are often overlooked and can lead to serious injury or death if not properly controlled. In addition to the human impact, the business can also be impacted. In one example from New York, a contractor fell 18 feet through an unprotected skylight to his death. An inquiry found workers were exposed to unguarded roof openings and roof edges, and there was failure to provide employees with any personal fall protection equipment. In that case, the U.S. Department of Labor levied a $1.2 million dollar penalty against the contractor’s employer.2

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More fall protection resources

Supplement this talk: Properly Wearing a Safety Harness

More on this topic: Construction Fall Protection Guide

Construction resources: Construction Risk Management

[1] US Bureau of Labor Statistics “National Census of Fatal Occupation Injuries in 2022.” Dec 19, 2023
[2] OSHA News Release, February 28, 2022. https://www.osha.gov/news/newsreleases/region2/02282022
[3] Source Oregon OSHA (Oregon OSHA’s Technical Manual)

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