From the Experts: Revised Rule on ‘Floor Openings’ Fall Protection Takes Effect Oct. 1

What is happening with the fall protection standard that the California Division of Occupational Safety and Health (Cal/OSHA) has been working on since 2019?

The Occupational Safety and Health Standards Board (OSHSB) has adopted revised Construction Safety Orders Section 1635 to address fall protection related to structural steel erection, specifically fall protection around floor openings and leading edges.

The Western Steel Council and District Council of Iron Workers (petitioners) filed Petition 570, which was approved for action by the Board on January 17, 2019.

The petitioners originally sought amendments to Section 1710, Structural Steel Erection, relating to protections around floor openings and leading edges. The petitioners proposed to add rules regarding the use of cones and bars as barricades for work involving openings, when work is considered as work in progress.

The petitioners’ recommended revisions were based on several years of onsite workers’ hours demonstrating an extensive track record about the safety record of the proposed process. An advisory committee was held, and revisions and fine tuning resulted in a cleaner and easier operating safety system.

The OSHSB determined that Section 1635 was the more appropriate section to amend.

Revisions

Section 1635 Floors, Walls and Structural Steel Framed Buildings, has been revised to incorporate a fall protection system to be referred to as the cone and bar barricade (CBB) system.

Simply stated, where a floor opening exists, the floor opening shall be barricaded by guardrails, the CBB system or be covered when not attended by steel erection personnel. The CBB is an alternative to the planking system

Where a CBB system is used, specific materials and construction are required. Specific colored cones are required — the cones are to be labeled and of a minimum height and weight. The cones are to be firmly connected to each other and maintained a maximum and minimum distance apart around the floor opening.

A new appendix to Section 1635 shows general cone locations and a personal fall protection device.

As with any process or employee procedure, employees are to be trained, and the training documented.

The regulation permitting the use of the CBB system was heard on December 19, 2024, adopted and filed with the Secretary of State on July 15, 2025, and takes effect on October 1, 2025.

More information about the revisions are available on the OSHSB’s website.

Mel Davis, Workplace Safety Expert, CalChamber

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