Rooftop Fall Protection: What OSHA Requires
Under the Occupational Safety and Health Act of 1970, employers are required to provide a safe and healthful place of employment. This is made clear in Section 5(a)(1), often referred to as the General Duty Clause, requiring employers to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
While true for all trades of General Industry and Construction, providing a safe and healthful workplace is especially important in the roofing industry. Exposures to hazards such as falls (through skylights, roof hatches, and perimeter roof edge work), tripping, improper storage of materials, and fire losses require proactive efforts for which OSHA has set regulations for protection and mandatory compliance.
In the roofing industry, exposures to falls occur most commonly at the perimeter edge and roof openings such as roof hatches, created or existing holes, or skylights.
OSHA Standards for Roof Openings
OSHA has developed standards to prevent workers in General Industry and in Construction from falling through skylights, roof walking/work surfaces, holes, and floor openings.
Roof hatch protection is addressed by OSHA standard 29 CFR 1910.23, Guarding Floor and Wall Openings and Holes. It states that, “every ladder-way, floor opening, or platform shall be guarded by a standard railing with standard toe-board on all exposed sides (except at the entrance to an opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into an opening.”
For additional information visit osha.gov. For info on deck structural integrity, read 1926.501(a)(2). And for skylight protection, read 1910.23(1)(4), 1926.501(b)(4)(i), 1926.501(b)(4)(ii), and 1926.501(b)(4)(iii).
OSHA Standards for Perimeter Roof Edge Protection
Per 1910.23(c)(1), every open-sided floor or platform four feet or more above an adjacent floor or ground level should be guarded by a standard railing (or equivalent) on all open sides except where there is an entrance to a ramp, stairway, or fixed ladder.
Perimeter roof edge fall protection is addressed in multiple OSHA standards in subpart M of 29 CFR 1926.501. Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is six feet or more above a lower level shall be protected from falling by the use of 1) guardrail systems, 2) safety net systems, or 3) personal fall arrest systems.
In the roofing industry, the most common fall protection practice of the three options is that of a personal fall arrest system.
A personal fall arrest system consists of the use of a body harness, connector (i.e., lanyard, self-retracting lifeline, rope grab), and an anchor point. In this system all three components are equally important; however, a suitable anchor point may be the most difficult component to establish. OSHA Standard [29 CFR 1926.502(d)(15)] states:
Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows:
- As part of a complete personal fall arrest system which maintains a safety factor of at least two 502(d)(15)(i); and
- Under the supervision of a qualified person 502(d)(15)(ii).
In addition, the following standards contained in 1926.501 all pertain to roofing fall hazards:
1926.501(b)(3) Hoist areas
1926.501(b)(6) Ramps, runways, and other walkways
1926.501(b)(8) Dangerous equipment
1926.501(b)(10) Roofing work on low-slope roofs
1926.501(b)(11) Steep roofs
1926.501(b)(14) Wall openings
Compared to other trades that operate with existing overhead structures that meet the 5,000 pounds of arresting force, roofing contractors must select the best option from off-the-shelf anchor points that will likely be at foot level and scrutinize the manufacturer’s specifications to ensure compatibility with the roof’s characteristics. When planning for a successful fall, roofing contractors must also try to eliminate or reduce swing falls and ensure that an appropriate clearance exists from the roof to the ground.
Further standards exist, which apply to roofing fall protection, specifically 1926 subpart H – Materials Handling, Storage, Use, and Disposal; 1926 subpart L – Scaffolds; 1926 subpart T – Demolition; and 1926 subpart X – Stairways and Ladders.