Do You Need Permanent Fall Protection on Your Roof?

July 16, 2019

If you have individuals working on the roof (e.g. changing filters, servicing HVAC units, repairing motors, etc.), you need to protect them. It’s not just important, it’s mandatory. If you have an employee exposed to a known hazard, you must provide a means to protect them and prevent injury. The U.S. Department of Labor outlines the requirement in OSHA’s 29 CFR 1910 Subpart D – Walking-Working Surfaces.

The rule applies to both horizontal and vertical surfaces – everything from flat working surfaces to ramps, stairways, and ladders. It addresses hazards such as roof edges, skylights and other openings a person could fall through, as well as cluttered or wet working surfaces. “When we think about fall protection, it’s not always a fall from a height, it’s also about making the surfaces safe,” explains Kirk Dighton, Safety Manager, D. C. Taylor Co., Cedar Rapids, IA.

Before the rule was revised, employers were required to protect rooftop workers with guard rails. With the final ruling on November 18, 2016 (effective Jan. 17, 2017), employers now have the flexibility to protect workers using a variety of fall protection equipment. There are a lot of choices, all of which fall into two categories: passive and active fall protection.

What is passive fall protection?

Passive fall protection solutions are stationary. They don’t require users to wear personal protective equipment (PPE) or actively engage with the system.

Among all of the passive options, guard rail  is the easiest way to enforce safety. When an individual climbs a ladder (fixed ladder systems over 24 feet require fall protection), a swing gate automatically closes behind him/her. The worker is now on the roof inside the guard rail barrier. Getting close to the edge means workers would have to consciously climb through the guard rail.

Warning lines should be used on elevations greater than 6 feet and placed 15 feet or more from the edge for non-roofing work. The flagging serves as a barrier to warn employees that they are approaching an unprotected roof side or edge. If this is the only form of fall protection employed, a designated safety monitor must be present to prevent individuals from stepping between the line and roof edge. Warning lines can be erected temporarily or for a more permanent solution, metal flags on cable provide greater durability. Because warning lines are easier for people to step through, they should only be employed with users who are educated about the requirement and dangers and with an enforced policy on designated area work.

Walking paths are designated areas of a walking-working surface where an employer allows an individual to be without additional fall protection, usually utilized for inspections and not for any maintenance-type activity.  This is a visual designation. You have to have a very strong policy that’s enforced and no other fall hazards associated in this area.

You wouldn’t hesitate to protect workers from falls through the roof when a hole is present, and yet skylights are exactly that. Most are not designed to endure the weight of a person. While guard rail can be installed around the skylight, you have other options. Skylight screens are permanent solutions. Installed over the skylight, they withstand up to 400 pounds of force. If infrequent maintenance on equipment near one skylight takes place, consider skylight nets, a temporary solution. A frame unfolds over top of the skylight to catch an individual if they trip into the skylight.

What is active fall protection?

Unlike the solutions already discussed, active fall protection requires PPE and engagement from the user.

Single point anchors are secured to a roof’s substructure and/or roof deck or counterweighted. Eyelets on top serve as easily accessible personal fall arrest tie-off points. Workers wearing a body harness and fall restraint lanyard connect to anchorage points capable of supporting 5,000 pounds. They can then work within a 6- to 10-foot radius of the anchor.

A horizontal lifeline system is comprised of roof anchors and a cable lifeline to which individuals wearing body harnesses connect a lanyard. Unlike a single point anchor, the horizontal lifeline gives workers more space within which to work safely.

User training and inspection is critical to ensure the systems installed are effective at protecting workers from falls. Workers should know how to properly inspect and put on a body harness, PPE, lanyards, connectors, carabiners, and snap hooks. They should be acquainted with the system and instructed on proper use. In case of a fall, they also should be familiar with descent and rescue.

What fall protection is best for my roof?

By both surveying your roof and evaluating the workers’ exposure, recommendations can be provided. Outsourcing this step is wise; most large roofing contractors offer this service in partnership with a fall protection equipment manufacturer. These professionals understand all the available options and what’s required for compliance. They can help you determine what the most practical approach is. Schedule a roof inspection with D.C. Taylor Co. today!