Construction Contract Administration

I would appreciate people's input and recommendations for best practices.

Comment from my experience: Some clients expect these services. The scope may range from installing tie-backs as part of a roof replacement to full systems for new buildings.

1. To what extent is the Architect responsible for designing roof fall protection systems?
2. Is the Arch responsible for designing systems to achieve OSHA compliance of the roof area?
3. Are they Base Services or Expanded Services?
4. Does the Arch typically include scope for their structural engineers

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James McLane AIA
Page & Turnbull
Los Angeles CA
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In it's pretty typical on industrial construction to provide a ladder to the roof (either exterior, or interior with a roof hatch). For cold storage, where roof access is more common and more frequent for maintaining the refrigeration system, we would provide either a ships ladder and or a stair tower. 

After OSHA changed the rules from 20ft with an intermediate landing and cage to 24 ft without a cage, switching to a harness for fall protection, we had to get creative with alternate options to avoid the cost of installing and maintaining harness systems. 

From an architectural standpoint, for 19 years, I  designed ladders and ladders with intermediate landings. I recently partnered with a structural engineer whose solution was to provide the cage  attached to the guardrail on the intermediate landing, so that the upper ladder would not be deemed greater than 24 ft.to the grade below. It's ironic because I contacted OSHA Representatives for months following the announcement of the change and none of them could give me a clear answer on the intermediate landing solution.

Typically, the structural engineer would either design the standard ladder from a steel fabrication standpoint as well as the structural attachment and or leave the ladder to be delegated designed by the steel fabricator.

Please let me know if you have any additional questions, from an industrial standpoint.

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Ben Trusty AIA
Atlanta GA
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One approach is to indicate where on the roof that protection is needed and defer to the contractor to source a compliant system.  Give them a detail for flashing of tubular penetrations, have the structural drawings indicate requirements for attaching (or, indicate what the maximum loads can be).

Don't forget fall protection at skylights.

In a kind of related question, what do you do about accessing the roof during construction?  Just go up there and walk over to the edge, or walk over to the edge and claim that the OSHA exemption for "inspection" applies to you (but not to construction workers), or have your own set of fall protection gear to clip in to the contractor's lines?

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Joel Niemi AIA
Joel Niemi Architect
Snohomish, WA
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Regarding construction access, I am typically required to be tied off using designated safety anchor points, contractor-installed lifelines, or similar systems. In most cases, access to these areas is restricted without appropriate fall protection measures in place.

While we provide our own fall protection equipment, the contractor (for the majority of our projects) conducts biannual inspections to ensure all gear meets or exceeds the applicable site safety standards. This may vary contractor to contractor, pending the rigor of their safety program. 

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Shaili Patel AIA
Colby Company Engineering
Palmer AK
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Original Message:
Sent: 04-03-2026 06:08 PM
From: Joel Niemi, AIA
Subject: Roof Fall Protection and OSHA Compliance

One approach is to indicate where on the roof that protection is needed and defer to the contractor to source a compliant system.  Give them a detail for flashing of tubular penetrations, have the structural drawings indicate requirements for attaching (or, indicate what the maximum loads can be).

Don't forget fall protection at skylights.

In a kind of related question, what do you do about accessing the roof during construction?  Just go up there and walk over to the edge, or walk over to the edge and claim that the OSHA exemption for "inspection" applies to you (but not to construction workers), or have your own set of fall protection gear to clip in to the contractor's lines?

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Joel Niemi AIA
Joel Niemi Architect
Snohomish, WA
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Hi Joel, Thanks for your reply. Our firm does mainly renovation and preservation work, and we do a lot of documenting existing conditions.  We are all trained in fall protection including use of harnesses. 

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James McLane AIA
Page & Turnbull
Los Angeles CA
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Original Message:
Sent: 04-03-2026 06:08 PM
From: Joel Niemi, AIA
Subject: Roof Fall Protection and OSHA Compliance

One approach is to indicate where on the roof that protection is needed and defer to the contractor to source a compliant system.  Give them a detail for flashing of tubular penetrations, have the structural drawings indicate requirements for attaching (or, indicate what the maximum loads can be).

Don't forget fall protection at skylights.

In a kind of related question, what do you do about accessing the roof during construction?  Just go up there and walk over to the edge, or walk over to the edge and claim that the OSHA exemption for "inspection" applies to you (but not to construction workers), or have your own set of fall protection gear to clip in to the contractor's lines?

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Joel Niemi AIA
Joel Niemi Architect
Snohomish, WA
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From a life safety perspective, we have implemented several measures. Where equipment is located within the designated distance from an edge, or where maintenance access is required, appropriate fall protection systems have been incorporated.

As the architect, we have coordinated closely with the structural engineer to ensure that all fall protection elements are designed within the required structural capacity and the locations are code-compliant. When fall protection is mandated for life safety, it is included in our base scope, and the structural engineer is fully informed of these requirements.

Additionally, depending on the jurisdiction in which you are practicing, standards beyond OSHA-such as NFPA 101, UFC, and others-may also apply and trigger these requirements.

Please let me know if you have any further questions.

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Shaili Patel AIA
Colby Company Engineering
Palmer AK
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Requirement	Responsible Party
IBC guardrails, roof hatch guards	Architect (on permit drawings)
Cal/OSHA EBM system (3+ story buildings)	Architect (designed into project)
Anchorage point layout & structural capacity	Architect + Structural Engineer
Fall protection during construction	General Contractor / Subcontractor
Fall protection for post-occupancy maintenance	Building Owner / Employer
PPE, harness training, enforcement	Building Owner / Employer
Anchor recertification every 5 years	Building Owner

Bottom line for your practice: As architect of record in Los Angeles, you are responsible for the code-mandated physical elements (guardrails, hatches, EBM anchors, structural anchorage points). OSHA operational compliance - training, PPE, enforcement, and ongoing recertification - is the owner's burden. The prudent approach is to design with post-occupancy OSHA compliance in mind and document that distinction clearly in your project manual.

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Jack Hillbrand Architect
Santa Monica, CA
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Thank you, Jack.

Regarding the EBM system: Do you recommend hiring a consultant to design the EBM system and prepare the OPOS? That would enable us to determine the anchorage points and loads, correct?

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James McLane AIA
Page & Turnbull
Los Angeles CA
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Original Message:
Sent: 04-04-2026 08:29 PM
From: Jack Hillbrand, AIA Member Emeritus
Subject: Roof Fall Protection and OSHA Compliance

Requirement	Responsible Party
IBC guardrails, roof hatch guards	Architect (on permit drawings)
Cal/OSHA EBM system (3+ story buildings)	Architect (designed into project)
Anchorage point layout & structural capacity	Architect + Structural Engineer
Fall protection during construction	General Contractor / Subcontractor
Fall protection for post-occupancy maintenance	Building Owner / Employer
PPE, harness training, enforcement	Building Owner / Employer
Anchor recertification every 5 years	Building Owner

Bottom line for your practice: As architect of record in Los Angeles, you are responsible for the code-mandated physical elements (guardrails, hatches, EBM anchors, structural anchorage points). OSHA operational compliance - training, PPE, enforcement, and ongoing recertification - is the owner's burden. The prudent approach is to design with post-occupancy OSHA compliance in mind and document that distinction clearly in your project manual.

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Jack Hillbrand Architect
Santa Monica, CA
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Original Message:
Sent: 4/27/2026 6:02:00 PM
From: James McLane, AIA
Subject: RE: Roof Fall Protection and OSHA Compliance

Thank you, Jack.

Regarding the EBM system: Do you recommend hiring a consultant to design the EBM system and prepare the OPOS? That would enable us to determine the anchorage points and loads, correct?

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James McLane AIA
Page & Turnbull
Los Angeles CA
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