California Construction Sites Face Uncertainty With New Fall Protection Rules

Quick Hits

• New California regulations, effective July 1, 2025, address fall protection plans and fall protection in residential framing and roofing operations.
• The Cal/OSHA Standards Board denied the residential construction industry’s request to extend the effective date to 2026 but authorized an advisory committee to consider clarifications and possible revisions to the July 1 regulation.
• Personal fall arrest systems (PFAS) frequently lack adequate clearance in interior framing; alternative methods can be impractical or may trigger citations under current interpretations.
• The rapid shift to the federal model has created uncertainty on active sites; variable field enforcement will challenge employers trying to determine what compliance looks like.

On July 1, 2025, new fall protection regulations went into effect in California, including a lowered trigger height from fifteen feet to six feet for most construction activities and requiring fall protection like guardrails, safety nets or personal fall arrest systems (PFAS), or fall restraint and fall positioning systems.

Compliance with these requirements in the context of interior framing would not only usually be infeasible, but would create a greater hazard for employees who may be required to work on ladders (a leading source of injuries) or rely on PFAS that require a significant deceleration distance and recovery space not available in most interior framing situations.

On March 18, 2025, industry leaders submitted a petition requesting an emergency extension of the effective date for the six-foot fall protection rule in residential construction. On April 14, 2025, the Western States Regional Council of Carpenters and Residential Contractors Association submitted a rare joint petition for emergency rulemaking to address these fall protection concerns. On July 31, 2025, the Standards Board Staff Evaluation, led by Senior Safety Engineer Simone Sumeshwar, submitted its opposition to both petitions but recommended that the Standards Board convene an advisory committee to consider possible clarifications to the rules and additional training requirements for employers.

On September 18, 2025, the Standards Board denied the request for emergency extension of the rule’s effective date to 2026, but voted unanimously for an advisory committee to consider limited changes and clarifications to the residential fall protection regulations. The Standards Board emphasized resource constraints and that authorizing an advisory committee would not reopen the broader policy debate. The Standards Board staff stated that FPPs must remain site-specific, while acknowledging the need to address limited options for interior framing work. The Standards Board noted that nonalignment with federal requirements could risk the federal Occupational Safety and Health Administration (OSHA) assuming enforcement authority over residential construction in California, but maintained that it made its decision without pressure from federal OSHA.

Next Steps

The implications for employers are immediate and apply throughout California.

• The six-foot fall protection rule remains in effect without delay. Fall protection plans (FPPs) must be site-specific, but clarifications for interior framing and training expectations may be forthcoming via the advisory process.
• Employers will likely encounter continued scrutiny and potential variability in enforcement pending any clarifications.
• Following Appendix E to OSHA’s FPP may become an expressly recognized compliance pathway if adopted, reducing ambiguity.

Ogletree Deakins’ Workplace Safety and Health Practice Group will continue to monitor developments and will provide updates on the California, Construction, and Workplace Safety and Health blogs as additional information becomes available.

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