Protection From Falling Objects
The employers must ensure toeboards used for falling object protection:
- Are erected along the exposed edge of the overhead walking-working surface for a length that is sufficient to protect employees below.
- Have a minimum vertical height of 3.5 inches (9 cm) as measured from the top edge of the toeboard to the level of the walking-working surface. Two-by-four inch lumber meets this requirement.
- Do not have more than a 0.25-inch (0.5-cm) clearance or opening above the walking-working surface.
- Are solid or do not have any opening that exceeds 1 inch (3 cm) at its greatest dimension.
- Have a minimum height of 2.5 inches (6 cm) when used around vehicle repair, service, or assembly pits. Toeboards may be omitted around vehicle repair, service, or assembly pits when the employer can demonstrate that a toeboard would prevent access to a vehicle that is over the pit.
- Are capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any downward or outward direction at any point along the toeboard.
- Where tools, equipment, or materials are piled higher than the top of the toeboard, paneling or screening is installed from the toeboard to the midrail of the guardrail system and for a length that is sufficient to protect employees below. If the items are piled higher than the midrail, the employer also must install paneling or screening to the top rail and for a length that is sufficient to protect employees below; and
- All openings in guardrail systems are small enough to prevent objects from falling through the opening.
- The employer must ensure canopies used for falling object protection are strong enough to prevent collapse and to prevent penetration by falling objects.
Grab Handles
The employer must ensure each grab handle:
- is not less than 12 inches (30 cm) long;
- is mounted to provide at least 3 inches (8 cm) of clearance from the framing or opening; and
- is capable of withstanding a maximum horizontal pull-out force equal to two times the maximum intended load or 200 pounds (890 N), whichever is greater.
In late 2025, Oregon OSHA inspected a residential construction site where a contractor was performing two-story framing work. During the inspection, compliance officers observed multiple hazards that exposed workers below to potential struck-by injuries from falling tools and materials. Along exposed second-floor edges and at an opening near a work area, there were no compliant toeboards in place to prevent objects from being kicked or knocked off the elevated surface.
Investigators documented that falling-object protection was not installed to standard: edge protection was incomplete, and areas with stored tools and materials lacked the added screening/paneling needed when items could exceed the height of a toeboard. In the same inspection, officers also identified ladder safety violations and missing PPE enforcement, indicating broader gaps in jobsite controls and oversight.
No injuries or fatalities were reported at the time of the inspection. However, Oregon OSHA determined the conditions created a high risk of serious injury or death, especially for workers operating or walking below active framing and material-handling areas.
Violations & penalties (as cited in the inspection):
- Fall protection failure (repeat offense): Workers performed tasks 6+ feet above a lower level without required fall protection. Penalty: $110,309
- Ladder side rails too short (repeat offense): Ladder side rails did not extend at least 3 feet above the landing surface. Penalty: $13,800
- Unprotected wall/opening hazard: No guardrails or covers were installed around a second-floor opening. Penalty: $1,412
- Use of defective ladder: A ladder with a broken anti-slip device was in use instead of being removed from service or tagged out. Penalty: $1,412
- Lack of eye protection: A worker used a pneumatic nail gun without required eye protection. Penalty: $1,412
Total penalties: $128,345 (adjusted based on company size).
What went wrong:
- Falling-object controls were not implemented on elevated work surfaces where tools and materials were actively used and staged.
- Edge protection lacked compliant toeboards and, where needed, screening/paneling to keep items from falling to lower levels.
- Unsafe ladder practices persisted, including defective equipment and improper extension above landings.
- PPE rules were not consistently enforced during high-risk tasks.
How this ties back to toeboard & falling-object requirements:
- Install toeboards along exposed edges for the full length needed to protect workers below.
- Use toeboards that meet minimum height requirements (2x4 lumber is commonly used to meet the 3.5-inch minimum).
- Keep clearance above the walking-working surface tight (no more than 0.25 inches) and prevent oversized openings.
- If materials are stacked above the toeboard height, add screening/paneling up to the midrail (or to the top rail if stacked higher) for adequate coverage.
- Use canopies where appropriate, ensuring they are strong enough to prevent collapse and penetration by falling objects.
Bottom line: falling-object hazards on residential framing sites are predictable and preventable. If you have people working below, treat edge protection and object containment as non-negotiable — because the first dropped tool can be the one that ends a career.
Source: Oregon OSHA News Release 2025-17
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