U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration

DIRECTIVE NUMBER: CPL 03-00-025

SUBJECT: National Emphasis Program - Falls

DIRECTORATE: Directorate of Construction

SIGNATURE DATE: April 24, 2023 EFFECTIVE DATE: May 1, 2023

ABSTRACT

Purpose: This instruction, National Emphasis Program on Falls, describes 

policies and procedures for implementing an OSHA National 

Emphasis Program (NEP) to identify and to reduce hazards which 

are causing or likely to cause serious injuries and fatalities from 

falls while working at heights.

Scope: This instruction applies OSHA-wide.

References: See Section III for a complete list of references.

Cancellations: See Section IV. Cancellations.

State Impact: Notice of Intent and Adoption required. See paragraph VI.

Action Offices: OSHA National, Regional and Area Offices, State Plan and OSHA 

On-Site Consultation programs.

Originating Office: Directorate of Construction (DOC).

Contact: Director, Office of Construction Services

200 Constitution Avenue, NW, Room N3468

Washington, DC 20210

Phone (202) 693-2020

By and Under the Authority of

Douglas Parker

Assistant Secretary
Executive Summary

This instruction provides guidance to Occupational Safety and Health Administration’s

(OSHA) National, Regional, Area, and State Plan offices for implementation of an OSHA 

National Emphasis Program (NEP) to reduce or eliminate workplace fall hazards 

associated with working at heights. Considering that falls remain the leading cause of 

fatalities and serious injuries in all industries, the agency has determined that an increase

in enforcement and outreach activities is warranted.

Significant Changes

None. This is a new instruction.
Table of Contents

I. Purpose............................................................................................................................. 1

II. Scope................................................................................................................................. 1

III. References. ....................................................................................................................... 1

IV. Cancellations..................................................................................................................... 3

V. Action Offices.................................................................................................................... 3

VI. Federal Program Change - Notice of Intent and Equivalency Required........................... 4

VII. Background. ...................................................................................................................... 4

VIII. NEP Goal. .......................................................................................................................... 6

IX. Procedures........................................................................................................................ 6

X. Recording in OIS................................................................................................................ 8

XI. Outreach. .......................................................................................................................... 9

XII. Program Review.............................................................................................................. 11

XIII. Appendix ......................................................................................................................... 11
1

I. Purpose.

This instruction describes policies and procedures for implementing a National 

Emphasis Program (NEP) to reduce or eliminate injuries and fatalities associated 

with falls while working at heights in all industries.

II. Scope.

A. This instruction applies OSHA-wide. All construction inspections related to 

falls will be conducted pursuant to this NEP.

B. For non-construction inspections, this NEP will target the following 

activities:

1. Roof top mechanical work/maintenance

2. Utility line work/maintenance (electrical, cable)

3. Arborist/tree trimming

4. Holiday light installation

5. Road sign maintenance/billboards 

6. Power washing buildings (not connected to painting)

7. Gutter cleaning

8. Chimney cleaning

9. Window cleaning

10. Communication Towers

C. For other non-construction work activities where a worker is observed 

working at height, an inspection may be initiated upon approval by area 

office management.

D. If an inspection is not warranted after entering the site and observing work 

activities, the CSHO will conduct an outreach activity on fall protection and 

exit the site. 

III. References.

A. 29 CFR Part 1910, Occupational Safety and Health Standards, 

https://www.osha.gov/laws-regs/regulations/standardnumber/1910.

B. 29 CFR Part 1910, Subpart D - Walking-Working Surfaces, 

https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910SubpartD.

C. 29 CFR Part 1910, Subpart I - Personal Protective Equipment, § 1910.140,

Personal fall protection systems, https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910.140.

D. 29 CFR Part 1915, Occupational Safety and Health Standards for Shipyard 
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Employment, https://www.osha.gov/lawsregs/regulations/standardnumber/1915.

E. 29 CFR Part 1915, Subpart E - Scaffolds, Ladders and Other Working 

Surfaces, https://www.osha.gov/lawsregs/regulations/standardnumber/1915/1915SubpartE.

F. 29 CFR Part 1915, Subpart I - Personal Protective Equipment (PPE), § 

1915.159, Personal fall arrest systems (PFAS), https://www.osha.gov/lawsregs/regulations/standardnumber/1915/1915.159, and § 1915.160,

Positioning device systems, https://www.osha.gov/lawsregs/regulations/standardnumber/1915/1915.160.

G. 29 CFR Part 1917, Marine Terminal, https://www.osha.gov/lawsregs/regulations/standardnumber/1917. 

H. 29 CFR Part 1917, Subpart F – Terminal Facilities, 

https://www.osha.gov/laws-regs/regulations/standardnumber/1917. 

I. 29 CFR Part 1918, Safety and Health Regulations for Longshoring, 

https://www.osha.gov/laws-regs/regulations/standardnumber/1918.

J. 29 CFR Part 1918, Subpart C - Gangways and Other Means of Access, 

https://www.osha.gov/lawsregs/regulations/standardnumber/1918/1918SubpartC.

K. 29 CFR Part 1918, Subpart D – Working Surfaces, 

https://www.osha.gov/lawsregs/regulations/standardnumber/1918/1918SubpartD.

L. 29 CFR Part 1918, Subpart H, Handling Cargo, https://www.osha.gov/lawsregs/regulations/standardnumber/1918/1918SubpartH.

M. 29 CFR Part 1918, Subpart J, Personal Protective Equipment, 

https://www.osha.gov/lawsregs/regulations/standardnumber/1918/1918SubpartJ.

N. 29 CFR Part 1926, Safety and Health Regulations for Construction,

https://www.osha.gov/laws-regs/regulations/standardnumber/1926.

O. 29 CFR Part 1926, Subpart M - Fall Protection, https://www.osha.gov/lawsregs/regulations/standardnumber/1926/1926SubpartM.

P. 29 CFR Part 1926, Subpart L - Scaffolds, § 1926.451(g), Fall Protection,

https://www.osha.gov/lawsregs/regulations/standardnumber/1926/1926.451#1926.451(g).

Q. 29 CFR Part 1926, Subpart R - Steel Erection, § 1926.760, Fall Protection, 

https://www.osha.gov/lawsregs/regulations/standardnumber/1926/1926.760. 

R. Federal Register, 59 FR 40672-40753, §§ 1910, 1926, Safety Standards for 
3

Fall Protection in the Construction Industry; Final Rule, August 9, 1994, and 

as amended.

S. OSHA Instruction, STD 03-11-002, Compliance Guidance for Residential 

Construction, June 16, 2011.

T. OSHA Instruction, ADM 04-00-003, OSHA Field Safety and Health Manual, 

May 6, 2020.

U. OSHA Instruction, CPL 02-00-025, Scheduling System for Programmed 

Inspections, January 4, 1995.

V. OSHA Instruction, CPL 02-00-051, Enforcement Exemptions and Limitations 

under the Appropriations Act, May 28, 1998 (including annually updated 

Appendix A).

W. OSHA Instruction, CPL 02-00-155, Inspection Scheduling for Construction, 

September 6, 2013.

X. OSHA Instruction, CPL 02-00-164, Field Operations Manual (FOM), April 14, 

2020.

Y. OSHA Instruction, CPL 02-01-064, Site-Specific Targeting (SST), February 7, 

2023.

Z. OSHA Instruction, CPL 02-01-169, OSHA’s Use of Small Unmanned Aircraft 

Systems, December 22, 2021.

AA. OSHA Technical Manual (OTM) TED 01-00-015, Section V, Chapter 4 -Fall 

Protection in Construction.

BB. Enforcement of Fall Protection on Moving Stock, 

https://www.osha.gov/laws-regs/standardinterpretations/1996-10-18.

CC. Procedures for Local and Regional Emphasis Programs, 

https://www.osha.gov/memos/2014-12-03/procedures-local-and-regionalemphasis-programs.

DD. Enforcement Inspection Guidance for Tree Care and Tree Removal 

Operations, https://www.osha.gov/memos/2021-06-30/inspectionguidance-for-tree-care-and-tree-removal-operations. 

IV. Cancellations.

REPs/LEPs that are substantially similar to this NEP should be cancelled. Those that 

have other elements in them can remain in effect. Phasing out of substantially 

similar REPs/LEPs should occur following the 90-day outreach period after 

publication of this NEP. 

V. Action Offices.

A. Responsible Office.

Directorate of Construction (DOC), Office of Construction Services (OCS).
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B. Action Office.

OSHA Regional Administrators, Area Directors, State Plan Designees, and 

National Office Directors must ensure that the policies and procedures set 

forth in this instruction are followed. Regional Administrators must also

ensure that Consultation Program Managers in their regions are informed of

the requirements of this instruction and encourage the involvement of OnSite Consultation programs in compliance assistance activities.

VI. Federal Program Change - Notice of Intent and Equivalency Required.

This Instruction describes a federal program change that implements OSHA’s NEP 

covering fall prevention in all industries. State Plans are required to have 

enforcement policies and procedures in place that are at least as effective as those 

in this Instruction. State Plans have the option of adopting an identical or different 

program, but the program must be at least as effective as this Instruction.

Within 60 days of the effective date of this Instruction, State Plans must submit a 

notice of intent indicating whether the State Plan will adopt or already has in place 

policies and procedures that are identical to or at least as effective as the federal 

program. State Plan adoption, either identical or different, shall be accomplished 

within six months. If adopting identically, the State Plan must provide the date of 

adoption to OSHA, due within 60 days of adoption. If the State Plan adopts or 

maintains a program that differs from this directive, the State Plan must identify 

the differences and may either post its policy on its website and provide the link to 

OSHA or submit an electronic copy to OSHA with information on how the public 

may obtain a copy. This action must occur within 60 days of the date of adoption. 

OSHA will provide summary information on the State responses to this Instruction 

on its website.

VII. Background.

A. Fall Fatalities.

Despite the balanced application of the agency’s outreach, enforcement, 

and compliance assistance efforts, fatalities caused by falls continue to be a 

leading cause of death for all workers. A comparison of the Bureau of Labor 

Statistics (BLS) and OIS data between 2014 and 2021 revealed the following:

All Industries 2014 2015 2016 2017 2018 2019 2020 2021

Total Fatalities 4,821 4,836 5,190 5,147 5,250 5,333 4,764 5,190

Fatal Falls –

Slips/Trips/Falls 818 800 849 887 791 880 805 850

Fatal Falls to Lower 

Level 660 648 697 713 615 711 645 680

Note: Falls to lower level accounted for 13% (5,369) of the 40,531 fatalities in all 

industries during this period. (Source BLS)
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Construction 2014 2015 2016 2017 2018 2019 2020 2021

Total Fatalities 899 937 991 971 1,008 1061 1008 986

Fatal Falls –

Slips/Trips/Falls 359 364 384 386 338 * 368 390

Fatal Falls to Lower 

Level 345 350 370 366 320 * 351 378

Note: Falls to lower level accounted for 32% (2,480) of the 7,861 construction 

fatalities during this period. (Source BLS)

* BLS Data not available for 2019.

Non-Construction 2014 2015 2016 2017 2018 2019 2020 2021

Total Fatalities 3,922 3,899 4,199 4,176 4,242 4,272 3756 4204

Fatal Falls –

Slips/Trips/Falls 459 436 465 501 453 * 437 460

Fatal Falls to Lower 

Level 315 298 327 347 295 * 294 302

Note: Falls to lower level accounted for 7% (2,178) of the 32,670 non-construction 

fatalities during this period. (Source BLS)

* BLS Data not available for 2019.

B. Inspections.

Inspections All 

Industries * 2014 2015 2016 2017 2018 2019 2020 2021

Total Inspections 36,163 35,820 31,948 32,408 32,023 33,393 21,710 24,333

Fall Emphasis 15,311 14,885 13,233 11,682 11,181 11,513 7,319 7,954

Note: Nearly 31% (77,782) of the 247,798 inspections OSHA conducted during this 

period had a fall emphasis. (Source OIS Inspection Summary Reports and Scan 

Summary Reports)

Construction 

Inspections * 2014 2015 2016 2017 2018 2019 2020 2021

Total Inspections 18,234 17,541 15,630 16,918 16,797 17,474 11,070 12,589

Fall Emphasis 12,855 12,473 11,214 10,585 10,298 10,485 6,606 7,205

Note: Roughly 65% (81,721) of the 126,253 inspections OSHA conducted in the 

construction industry during this period had a fall emphasis. (Source OIS Inspection 

Summary Reports and Scan Summary Reports)

Non-Construction

Inspections * 2014 2015 2016 2017 2018 2019 2020 2021

Total Inspections 17,929 18,279 16,318 15,490 15,226 15,972 10,676 11,744

Fall Emphasis 2,456 2,412 2,019 1,097 883 1,028 713 749

Note: Roughly 9% (11,357) of the 121,634 inspections OSHA conducted during this 

period had a fall emphasis. 

(Source OIS Inspection Summary Reports and Scan Summary Reports)
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* Source - Annual Enforcement Report

C. Consultation Data.

Consultation 

Visits - All 

Industries

2014 2015 2016 2017 2018 2019 2020 2021

Total Visits 19,694 22,480 27,836 26,315 26,602 26,213 17,663 17,607

Fall Emphasis * 17 470 4,460 4,903 4,230 4,731 2,231 2,154

Note: Roughly 13% (23,196) of the 184,410 consultation visits in all industries during 

this period were fall related.

* Information was not comprehensively captured until 2016. (Source OIS) 

Construction 

Consultation 

Visits

2014 2015 2016 2017 2018 2019 2020 2021

Total Visits 4,767 5,912 8,400 8,208 8,459 7,821 5,643 5,235

Fall Emphasis * 7 304 2,667 3,175 2,174 2,563 1,681 1,383

Note: Roughly 26% (13,954) of the 54,445 consultation visits in the construction 

industry during this period were fall related.

* Information was not comprehensively captured until 2016. (Source OIS)

Non-Construction 

Consultation 

Visits

2014 2015 2016 2017 2018 2019 2020 2021

Total Visits 14,927 16,568 19,436 18,107 18,143 18,392 12,020 12,372

Fall Emphasis * 10 166 1,793 1,728 2,056 2,168 550 771

Note: Roughly 7% (9,242) of the 129,965 consultation visits in the non-construction 

industries during this period were fall related.

* Information was not comprehensively captured until 2016. (Source OIS)

VIII. NEP Goal.

The goal of this NEP is to significantly reduce or eliminate unprotected worker 

exposures to fall-related hazards in all industries that can result in serious injuries 

and deaths. OSHA’s goal will be accomplished by a combination of enforcement 

(which includes hazard-based inspection targeting and optional locally-generated 

programmed targeting in construction as outlined in Appendix A), outreach to 

employers, and compliance assistance. OSHA anticipates that most of the 

inspections will occur in construction because the majority of the fatal falls to lower 

levels each year occur on construction worksites.

IX. Procedures.

A. Programmed inspections under a new NEP are typically initiated after a 90-

day outreach period, as required for LEPs and REPs in accordance with 

OSHA Memorandum on Procedures for Local and Regional Emphasis 

Programs, December 3, 2014. See Section XI for required outreach 
7

activities.

B. Compliance Safety and Health Officers (CSHOs) must never put themselves 

in harm’s way while conducting an inspection. Supervisors shall ensure 

CSHOs comply with all safety and health guidance and requirements 

developed as part of ADM 04-00-003, OSHA Safety and Health Management 

System (SHMS), particularly Chapters 11 - Walking and Working Surfaces

and 17 - Fall Protection. CSHOs should review and follow all Regional SHMS 

policies and procedures to be prepared for foreseeable hazards which may 

arise during the inspection. The use of Small Unmanned Aircraft Systems 

(SUAS) to conduct certain inspections is encouraged as another means of 

protecting CSHOs during inspections. SUAS must be used as outlined in CPL 

02-01-169, OSHA’s Use of Small Unmanned Aircraft Systems.

C. CSHOs are authorized to initiate inspections under the scope of this NEP 

whenever they observe someone working at heights. These observations 

may occur during the CSHO’s normal work-day travel or while en route to, 

from, or during, other OSHA inspections. If a potential imminent danger 

condition exists, an inspection shall be initiated in accordance with the Field 

Operations Manual (FOM) Chapter 11 and document in the case file diary.

Inspections related to falls will also be initiated as the result of incidents, 

referrals, and complaints.

D. CSHOs shall contact the Area Office to obtain supervisory authorization to 

begin an immediate inspection.

E. If the CSHO cannot contact the Area Office (e.g., no cellular phone service 

or land-line and when no supervisors are immediately available) to get 

authorization, they shall initiate an immediate inspection provided this 

activity will not interfere with any higher priority inspections or 

assignments. In these cases, the CSHO will give highest priority to 

preventing further employee exposures where fall hazards were observed.

F. When CSHOs observe fall hazards but are unable to begin an immediate 

inspection (e.g., responding to an incident, etc.), they shall notify the Area

Office of their observations. In such cases, CSHOs will provide the Area 

Office with the following information:

1. The name, address, and/or location of the worksite;

2. The state and condition of the worksite operation, including any 

apparent serious hazards; and,

3. The name of contractor performing the operation (if known) and the 

number of workers observed.

G. Fall hazards referrals brought to the attention of the Area Office shall be 

evaluated, and, if appropriate, inspected.

H. Whenever an inspection is initiated under this NEP based on a CSHO self-
8

referral, the CSHO shall include in the case file narrative a description of the

circumstances which prompted the inspection. The case file shall indicate if

supervisory consent for the inspection was obtained prior to the start of the

inspection, or an explanation why this consent was not obtained.

I. During all programmed safety and health inspections (such as national, 

regional or local emphasis programs), and during all un-programmed 

inspections (incidents, complaints, and referrals), CSHOs shall observe the 

surrounding area for potential fall exposures and conduct an inspection

under this NEP if any are present.

J. The scope of inspections initiated under this NEP shall be conducted in 

accordance with the Field Operations Manual (FOM) and shall normally be 

limited to evaluating worker exposure to hazards associated with falls.

However, a CSHO may expand the scope of an inspection under this NEP if

there is evidence from injury and illness records, plain view hazards, or 

employee interviews of other potential safety and health hazards or 

violations at the worksite. CSHOs shall follow the guidelines in the FOM 

when expanding the scope of any inspection (Chapter 3, Section III.B.2).

K. At the end of each NEP inspection, the CSHO/AO will provide the employer 

with information concerning OSHA fall protection requirements and 

protective measures that should be implemented. For example, the

CSHO/AO may give the employer the website address for OSHA’s fall 

prevention standards and related outreach materials or provide copies of 

OSHA publications (resource dependent).

X. Recording in OIS.

A. All construction enforcement activities (i.e., inspections, complaints, and 

referrals, etc.) and compliance assistance interventions conducted under 

this NEP must be coded with “FALL” under the NEP Code field. 

B. All non-construction enforcement activities falling under the scope of this 

NEP (See Section II) must be coded with “FALL” under the NEP Code field.

C. Compliance assistance activities related to fall prevention will be coded with 

the NEP Code “FALL” as well as the applicable Topic(s) (e.g., Fall PreventionAll Construction; Fall Prevention- Residential Construction; Fall StandDown).

D. All consultation activities (Request, Visit, and Compliance Assistance) 

conducted in response to this NEP will also be coded “FALL” into OIS.

E. Enforcement and consultation activities related to fall hazards discovered 

under other NEPs and/or LEPs must be coded for all the NEPs and LEPs. For 

example, consultation activities related to fall hazards conducted under the 

Silica NEP must be coded “RCS-NEP” as well as “FALL.” Likewise, if fall 

hazards are observed during an inspection initiated under a construction 
9

targeting list, the “CTARGET” code must also be used as well as “FALL.”

XI. Outreach.

A. The National Office will conduct nationwide outreach upon issuance of this 

NEP, and periodically, using public announcements and communications to 

media, stakeholders, and alliances.

B. Each Area Office and Regional Office must develop and implement a 

comprehensive fall prevention awareness outreach program for 90 days 

prior to initiating inspections under this NEP. Area Offices and Regions must 

continue at least quarterly outreach efforts after the initial 90-day outreach 

period has concluded. Suggested outreach activities are as follows:

1. Write letters or news releases for local and national news

organizations announcing the implementation of this NEP. Trade

magazines can also assist with disseminating information about this

NEP.

2. Conduct outreach activities such as seminars/informational sessions 

for employer groups, trade associations, as well as worker groups 

(including national and local unions).

3. Provide outreach material to local licensing/permitting and other

municipal agencies for distribution to employers when they request 

construction permits.

4. Provide outreach material to truss manufacturers, roofing material 

supply companies, and major/local roofing companies for 

distribution to employers/employees.

5. Provide outreach material to industry associations and equipment 

rental organizations for distribution to membership and clients.

6. Collaborate with OSHA State Plan and cooperative program 

participants, including Voluntary Protection Programs, Strategic 

Partnership, and Alliance Program participants, to share success 

stories and technical information concerning effective means of 

controlling, reducing, or eliminating fall injuries and fatalities.

7. Collaborate with OSHA On-Site Consultation programs on strategic

approaches for assisting employers with fall prevention safety at 

worksites.

C. OSHA compliance assistance resources include:

1. Fall Protection in Construction - OSHA 3146-2015.

2. Construction: Protecting Roofing Workers - OSHA 3755-2015.

3. OSHA Construction eTool - Construction: Falls (English and Spanish).

4. OSHA v-Tool - Falls in Construction/Floor Openings
10

(English/Spanish).

5. OSHA v-Tool - Falls in Construction/Skylights (English/Spanish).

6. OSHA v-Tool - Falls in Construction/Leading Edge Work

(English/Spanish).

7. OSHA v-Tool - Falls in Construction/Reroofing (English/Spanish).

8. National Campaign to Prevent Falls in Construction.

9. National Safety Stand-Down to Prevent Falls in Construction.

10. Heat Stress Safety and Health Topics Page.

11. Construction Focus Four.

12. Shipyard Employment: Walking-Working Surfaces and PFPS Standard 

FAQs.

13. Marine Terminal Fall Protection for Personnel Platforms (osha.gov).

14. Aerial Lift Fall Protection over Water in Shipyards.

15. Fall Protection Safety Fact Sheet for Commercial Fishing.

16. Additional OSHA fall related compliance assistance material.

D. Area Offices should consider establishing Partnerships and Alliances with

employer groups, particularly small employers, and with worker 

representatives in the industry to share information concerning effective 

means of controlling and reducing employee exposures, and on workers’ 

rights, including the right to a safe and healthful workplace. Examples, many 

with regional and local affiliates, include:

1. NRCA - National Roofing Contractors Association.

2. NAHB - National Association of Home Builders.

3. AGC - Associated General Contractors of America.

4. ABC - Associated Builders and Contractors.

5. United Brotherhood of Carpenters and Joiners of America.

6. Ironworkers - International Association of Bridge, Structural, 

Ornamental and Reinforcing Iron Workers.

7. United Union of Roofers, Waterproofers & Allied Workers.

8. Laborers’ International Union of North America.

9. United Association of Journeyman and Apprentices of the Plumbing 

and Pipefitting Industry of the United States and Canada.

10. National Grain and Feed Association (NGFA).

11. Grain Elevator and Processing Society (GEAPS).
11

12. Grain Handling Safety Coalition (GHSC).

13. National Chimney Sweep Guild.

14. National Heating Ventilation and Air Conditioning Association.

E. To place more emphasis on vulnerable workers, Regions should also identify 

worker groups with a significant number of construction workers and inform 

them of their rights and what kind of fall protection measures they should 

expect their employer to provide in the workplace. These not only include the 

stakeholders listed above, but may include organizations representing day 

laborers, worker centers, and community groups. Engagement should be 

focused on building relationships that enable OSHA to effectively intervene to 

address fall hazards when they are occurring.

F. Small businesses should be encouraged to contact their local OSHA On-Site 

Consultation program for assistance. OSHA’s On-Site Consultation Program 

offers no-cost and confidential safety and health services to small- and 

medium-sized businesses in all 50 states, the District of Columbia, and 

several U.S. territories, with priority given to high-hazard worksites.

Consultants from local agencies or universities work with employers to 

identify workplace hazards, provide advice for compliance with OSHA

standards, and assist in establishing and improving safetyand health 

programs. On-Site Consultation services are separate from enforcement 

and do not result in penalties or citations. To locate the OSHA On-Site 

Consultation program nearest you, call 1-800-321-OSHA (6742) or visit

www.osha.gov/consultation. 

XII. Program Review.

To assess the effectiveness of this NEP, DEP and DOC will review this NEP within six 

months of issuance, per ADM 03-00-003, to determine whether the policy will be 

continued, and take any necessary steps to assure its replacement with a cleared 

Instruction. The program review will include data analytics of fall hazards and 

citations. The results will be shared with the Regions for consideration for 

enforcement and outreach activities. The review shall also address the NEP goal 

(see Section VIII), in accordance with established Agency procedures. 

XIII. Appendix

The following appendix is provided as additional guidance for developing a targeted 

system to inspect local construction sites. Regions and Area offices are encouraged 

to develop targeting methods that effectively reach industry sectors where fall 

protection is often lacking, such as residential construction and servicing activities. 

Please consult with DOC or DEP, dependent on the work activity, and the Office of 

the Solicitor - Occupational Safety and Health Division, on permissible methods.
12

Appendix A: Locally Generated Programmed Construction Targeting
13

APPENDIX A: Locally Generated Programmed Construction Targeting

1. Procedures.

A. The Area Director shall be responsible for developing a list of 

establishments for inspections. The establishment list will be generated as 

follows. Based on local knowledge obtained from sources such as media, 

unions, community groups, building departments, etc., the Area Director 

will select a distinct geographic area within each respective Area Offices 

jurisdiction. The boundaries of the area will be defined based on the Postal 

ZIP code, police precinct, political district or neighborhood, or significant 

geographic features (e.g., bodies of water, main thoroughfares, etc.).

B. An OSHA employee will be assigned to travel throughout the selected

geographic area. All ongoing construction projects observed will be listed, 

including active and inactive projects, regardless of observed hazards. Cues 

for ongoing projects include actual construction work, scaffolding, sidewalk 

sheds, construction barricades and fencing, posted building permits, 

demolition dumpsters, and the presence cranes and heavy equipment. If 

possible, the entire selected geographic area will be surveyed the same 

business day.

C. The OSHA Area Office will compile the list of each ongoing project to 

include the following minimum information: street address, type of 

construction activity, and other site observations. If possible, the identity 

of the employer will also be listed. Any hazards observed, including hazards 

related to employees working at heights, shall be noted as well. The 

establishments will be listed sequentially in the order in which they are 

observed.

D. If hazards are observed by the OSHA employee, they shall be reported to

the Area Office (AD/AAD). If imminent danger conditions are observed, an 

inspection shall be initiated following appropriate protocols as

described in the current Field Operations Manual and applicable National 

Emphasis Programs.

E. When performing programmed inspections under this NEP, each Area 

Office shall develop an inspection master list of establishments. The 

National Office Policy on List Generation and Randomization shall be 

followed in accordance with the National Office Memorandum to Regional 

Administrators dated November 12, 2014, Establishment Targeting Lists for 

Emphasis Programs. Deletions and scheduling must be completed in 

accordance with CPL 02-00-155, Inspection Scheduling for Construction.

F. If the Area Director determines that the list is no longer representative of 

the status of work in the defined area, or that sufficient inspection 

resources have been devoted to the selected geographic area, a new field 

survey shall be conducted using the same criteria defined above, and a new 
14

list will be generated. This new survey may be of the same geographic area 

or of another one.

G. The scope of these inspections shall be as outlined in paragraph II.A and IV.J 

of this NEP. 

H. Establishments for inspection may fall within the scope of the current 

Appropriations Act. If so, inspection activities must be done and completed 

in accordance with the directive, CPL02-00-051, Enforcement Exemptions 

and Limitations under the Appropriations Act

I. Recording in OIS. See paragraph X. Recording in OIS, in the NEP for coding 

instructions.