Nothing about fall protection changed on September 1. But OSHA put a number on how many construction employers the standard actually touches, and the number is 449,782.
The agency asked the Office of Management and Budget to reauthorize the paperwork behind 29 CFR 1926.502 and 1926.503 for another three years, under control number 1218-0197. The supporting estimates are the news: 449,782 private-sector construction employers, 6,715,846 responses a year, and 560,607 hours of burden.
What the standard asks you to write down
Three obligations are covered. Section 1926.502(c)(4)(ii) requires certification of safety nets. Section 1926.502(k) requires a written fall protection plan where one is used in place of conventional protection. And 1926.503(b) requires a training certification record carrying the worker’s name or identifier, the date or dates of training, and the signature of the competent person who conducted it, or of the employer.
That last one is the record most contractors actually generate, and it is where the six-million-response figure comes from. Note the competent-person requirement: the training has to be delivered by one, and the record has to be signed by one.
Do the division
560,607 hours across 449,782 employers works out to about 1.25 hours per employer per year, and roughly five minutes per record. OSHA also puts the annual other-costs burden at $0, meaning it assumes no out-of-pocket expense beyond staff time.
Anyone who has assembled a fall-protection training file for a jobsite audit will have a view about five minutes a record and zero dollars. The agency has left the door open on exactly that point: the notice specifically invites comment on “the accuracy of the agency’s estimates of the burden and cost of the collection.” Comments are due to OMB by October 1, 2026, through reginfo.gov under the 30-day review list.
These are agency estimates submitted for approval, not measured data, and the notice says so. But they’re the only public count of how wide Subpart M reaches, and 449,782 employers is a useful denominator the next time somebody quotes a fall-protection citation total.
Related on Exchange: roof work at the Nelson-Atkins Bloch Building.
Sources: Federal Register, September 1, 2026; prior 60-day notice at 90 FR 58623, December 17, 2025.