The 3 Biggest Myths About Rooftop Fall Protection
Facilities/plant managers are responsible for a lot; it’s no wonder they’re unaware or confused about requirements for fall protection. D. C. Taylor Co.’s Safety Manager Kirk Dighton busts the three most common myths in this month’s blog.
Myth 1: “I hire contractors to do the HVAC work on my roof. Fall protection is on them, not me!”
The responsibility for job site safety is shared between the contractor and the building owner. “It’s a two-way street. If we are hired to do a roofing project, it’s our responsibility to ensure that our people are safe, but it’s also the customer’s responsibility to ensure that we are safely doing the project,” explains D. C. Taylor Co. Safety Manager Kirk Dighton.
Specifically, liability in the event of an incident could shift to the building owner if negligence is perceived (for example, if hazards were known and not discussed/addressed) or if the owner took on the role of construction manager for work being performed.
Myth 2: “That 30-foot fixed ladder with the cage was new in 2010. I don’t have to install fall protection on it.”
“At one time, that cage was determined to be fall protection. Basically, the only thing it’s good for, though, is when you’re climbing up this tall ladder and you get tuckered out, you can lean back against it so you can rest,” says Dighton. “But if you fall without any fall protection or any fall arrest, it’s like a pinball inside a cage. You can pinball right down through it.” For this reason, OSHA put new guidelines in place.
For fixed ladders that extend more than 24 feet above a lower level, employers must equip them with a personal fall arrest system or ladder safety system before Nov. 18, 2036. Additionally, according to OSHA 1910.28(b)(9)(i)(C), if you’re doing any maintenance on this ladder before that time, it should include the installation of a personal fall arrest system or ladder safety system.
Myth 3: “My maintenance team only goes to the roof two times per year to chase leaks. I don’t need a plan or to train them in fall protection and they sure don’t need harnesses.”
Whether this is a myth or not depends on a few factors. If the work being performed on the roof is infrequent or temporary and individuals stay 6 feet away from the roof edge, no fall protection is required; however, they must stay in a designated area, at least 6 feet (but preferably 15 feet) away from the roof edge to work without any fall protection (e.g., guard rail, safety net, or personal fall arrest system). Erect a flag line as a visual reminder of the boundary.
Wondering what temporary and infrequent mean? OSHA has defined temporary as tasks that usually take less than 1-2 hours to complete. Infrequent refers to work that occurs once per month, once per year, or as needed, like when a piece of equipment breaks down. Unfortunately, as Dighton points out, even a warning line may not be enough to keep workers from danger. “People have a tendency to go under warning lines thinking, ‘I’ll just quickly do this and duck right back in,’” he says. “Along with that designated area, you have to have a pretty good compliance status and be able to enforce it.” This is where training is necessary. You need to explain and teach what the requirements are and why it’s important to avoid risky uncompliant behavior.
Work that happens regularly or takes longer than two hours requires fall protection. “OSHA is starting to observe general industry. Anybody up on the roof? They’re going to swing in and say, ‘Hey, show me the fall protection for your individuals up on the roof,’” says Dighton.
The best response to these requirements and the easiest way to avoid an accident, injury, or death, is to install fall protection. OSHA’s 1910.28 gives you a wealth of options (e.g., guard rail, single-point roof anchor, horizontal lifeline, roof hatch, skylight screens, etc.).
Talk with D. C. Taylor Co. about evaluating your needs for fall protection equipment today. Call us at 319.731.4118 or email [email protected].