8 CCR 1716.2 Update: Where the California Framing Rule Stands

Was the California 6 foot framing rule delayed?

No. The amended 8 CCR 1716.2 has been operative since 1 July 2025 and has never been stayed, suspended or delayed. The petition asking the Occupational Safety and Health Standards Board to push the date to 1 July 2026 was denied on 18 September 2025.

This page exists because the opposite is still circulating on California job sites. It sets out what the operative text says, what the challenge to it actually achieved, and what is being drafted next.

What exactly changed in 1716.2 on 1 July 2025?

The amendment was filed 26 November 2024 and became operative 1 July 2025, Register 2024 No. 48. The regulation history records the change precisely, and it is worth reading as a redline rather than as a headline.

  • Amended: the section heading, and subsections (a), (b)(7), (e)(1), (f), (g)(1) and (i)(2).
  • Repealed: subsection (b)(10), the two exceptions that used to sit under (e)(1), and the carve outs that used to sit under (g)(1)(A) through (g)(2).
  • New: subsections (e)(2) through (e)(2)(C), and (f)(1).
  • Renumbered and amended: the newly designated (g)(2).

In plain terms, four things moved:

  1. The trigger height on structural members went to 6 feet. Under (e)(1), walking or working on top plates, joists, rafters, trusses, beams or similar members 6 feet or more above the grade or floor below now requires scaffolding, guardrails, safety nets, personal fall protection systems, or a fall protection plan with safety monitors and controlled access zones where the employer first demonstrates that conventional methods are infeasible.
  2. The old exceptions under (e)(1) were deleted. Their substance was rewritten into the new (e)(2), which is a conditional pathway, not an exemption. Read the three conditions on our interior framing exception page.
  3. Starter board, roof sheathing and fascia board moved to 6 feet under (g)(1), and the carve outs that used to follow it were repealed.
  4. Work outside the gable end truss or rafter became its own paragraph at (g)(2), at 6 feet.

The scope language in (a) and the definition in (b)(7) were also amended. The section now applies to residential type and light commercial framing, and the definition states expressly that residential type framing activities include the framing of commercial structures that use traditional wood frame construction materials and methods.

What happened to Petition 607?

Both of the things the petitioners asked for were refused. The only thing granted was an advisory committee.

In Petition File No. 607, Kevin D. Bland filed on behalf of the Housing Contractors of California, the California Framing Association, the Residential Contractors Association and the Western States Regional Council of Carpenters. The petition asked the Board either to extend the effective date from 1 July 2025 to 1 July 2026 by emergency rulemaking, or in the alternative to adopt a new section 1671.3 creating a separate fall protection plan for interior residential framing.

The adopted decision, dated 18 September 2025, is direct. Delaying the effective date "would unreasonably postpone the health and safety measures required by federal law." The proposed section 1671.3 "would provide less safety than the current title 8 regulations." The decision also records that either proposal "could trigger Federal OSHA enforcement authority."

The order granted the petition "to the limited extent that an advisory committee be convened" to consider two things: possible clarifications to and full adoption of the applicable federal OSHA Appendix E language and the existing site specific fall protection plan for interior framing work, and additional training requirements for implementing compliant site specific plans.

There is a trap in the numbering. The advisory committee that resulted is filed on the Board calendar under "Section 1671.3." That is the same number the Board rejected. The committee number is a label for the discussion, not evidence that the petition succeeded.

What did the 1671.3 advisory committee actually do?

It met once, on 13 May 2026, as a virtual meeting. Its remit was discussion, not adoption.

The Board describes the committee as convened to "discuss the need for possible clarifications to and full adoption of applicable Federal OSHA Appendix E language and the existing site specific fall protection plan to address the interior work framing activities, and consider additional training requirements." The agenda, invitation, roster, the federal Appendix E sample plan, the attended roster and the full transcript are posted on the committee page.

An advisory committee cannot change a regulation. It informs a proposal that the Board may or may not later notice for public hearing. Nothing was adopted, and nothing about the operative 1716.2 changed as a result.

Is another change to 1716.2 coming?

Yes, and it is larger than the one that has already happened. It is being worked under a separate advisory committee called Fall Protection in Construction Phase 2, covering sections 1669, 1670, 1671, 1716.2, 1724, 1730 and 1731.

The driver is stated on the Board's own committee page. On 12 July 2024 federal OSHA wrote to the Standards Board asking that items not at least as effective as the federal standard be addressed expeditiously "to avoid reaching an adverse ALAE determination with respect to the California State Plan." That is the mechanism by which a state plan can lose federal approval, and it is why these amendments keep moving even when the industry objects.

The most consequential item for framers sits in a follow up letter dated 11 June 2025 from James D. Wulff, Regional Administrator of the OSHA San Francisco Regional Office. Two points in it matter.

First, California's own Phase 2 draft would rewrite the final sentence of (e)(2) so that an employer meeting conditions (A) through (C) "shall use a fall protection plan with safety monitors and controlled access zones as described in Sections 1671.1 and 1671.2 unless fall protection is determined to be infeasible," in place of the current "may use." OSHA replied that this reads as though conventional fall protection is no longer an option under (e)(2), and said that is not at least as effective as the federal standard.

Second, and more bluntly: OSHA wrote that the term "interior framing activities" is undefined, that the provision does not clearly state when an employer is engaged in them or what compliance looks like, and that "OSHA recommends deleting Section 1716.2(e)(2) and requiring all employers to follow Section 1716.2(e)(1)."

That is a recommendation in a letter, not a rule. But it is the federal position on the record, and it points the opposite way from what the petitioners asked for. If it is followed, the interior framing pathway does not get clarified. It goes away, and every framer in the 6 to 15 foot interior band is back to demonstrating infeasibility.

What else is in the Phase 2 discussion draft?

The post meeting discussion draft carries proposed amendments well beyond framing. These are drafts for discussion. None of them is law.

  • Section 1669(a): the trigger for work from thrustouts, trusses, beams, purlins or plates would drop from 15 feet to 6 feet, and the word "infeasible" would become "impracticable."
  • Section 1670(a): the trigger for personal fall arrest, restraint and positioning systems would drop from 7 and a half feet to 6 feet, at the perimeter of a structure, unprotected sides and edges, leading edges, shaftways and openings, and roof surfaces steeper than 7:12. Subsection (g) would move from 7 and a half feet to 6 feet for the same reason.
  • Section 1671: the safety net provisions would be restructured, including a table setting the minimum horizontal distance of the outer edge of the net by the vertical drop, 8 feet up to a 5 foot drop, 10 feet from 5 to 10 feet, and 13 feet above 10 feet up to 30 feet.
  • Section 1724(h)(1): roofing material ramps and runways would need standard guardrails on both sides above 6 feet instead of above 20 feet.
  • Section 1730: the 20 foot roof trigger would become 6 feet at subsections (b)(1), (c), (e) and (f).
  • Section 1731: aligned with 1730 on how fall height is measured.

The 1670 change is the one with the widest reach. It is not a framing rule. It would apply to every construction trade in California that uses a harness.

Has any of Phase 2 been adopted?

No. As of 9 September 2026 no notice of rulemaking has been published for any of it, and no public hearing has been scheduled. We checked the Standards Board list of rulemaking proposals scheduled for hearing or adoption on that date. The most recent notice on it is unrelated to fall protection.

Phase 2 is at the advisory committee stage. Between here and an operative rule there is a formal notice, a 45 day comment period, a public hearing, usually one or more 15 day notices of modification, a final statement of reasons, review by the Office of Administrative Law, and an effective date. Phase 1 took from a public hearing in January 2024 to an operative date in July 2025, and the underlying advisory work started in 2016.

So there is nothing in Phase 2 to comply with today. There is also nothing in it that has been withdrawn.

What should a California contractor do about this now?

Three things, in this order.

  1. Comply with the operative text, not the commentary. The 6 foot trigger in (e)(1), the three conditions in (e)(2), the 6 foot trigger for sheathing and fascia in (g)(1) and for gable end work in (g)(2) are all in force today.
  2. Do not plan around a delay. The delay was requested and denied, and the decision explains why a second request would face the same federal constraint.
  3. Do not build a program that depends on (e)(2) surviving. The federal recommendation on the record is to delete it. A program that can also work under (e)(1), using a named conventional method, does not care which way that goes.

If you want the underlying reading rather than the summary, the sources are all public and all linked below.

Related guides

Primary sources

By Matthew Horovitz, M Squared Safety Solutions, Inc., 981 Calle Negocio Suite 200, San Clemente, CA 92673, 949-954-6581. Published 9 September 2026. Every regulatory statement on this page was read against the operative Title 8 text and the Occupational Safety and Health Standards Board rulemaking file on that date. This page describes what the regulations say. Whether a given provision is satisfied on a particular job is a determination for that employer and its own competent person.