Falls are the leading cause of injury and death among roofers. Subsequently, there are a variety of safety requirements for protection from falling in the construction roofing industry. OSHA 29 CFR 1926.501 Fall Protection General Requirements is consistently the most violated OSHA standard in construction. Common violations under this standard include failure to provide protection from falling near unprotected sides or edges and on both low-slope and steep roofs. In addition to protection from falling, there are further considerations for OSHA roof safety. First of all, let’s begin with the OSHA fall protection requirements for roof work safety.
Recommended Practices for Safety Programs
OSHA published “Recommended Practices for Safety & Health Programs in Construction” for fostering a proactive approach in dealing with construction job site hazards. This publication helps employers develop programs for workplace safety. The recommendations can be adjusted to the size of the company or for handling short-term or long-term projects. Seven core elements, all interrelated, of recommended practices are:
- management leadership – to provide resources to implement an effective safety and health program.
- worker participation – allows a program to benefit from the worker’s knowledge. This also empowers workers to provide feedback.
- hazard identification and assessment – identifies root cause(s) of construction injuries.
- hazard prevention and control – for safe and healthy working conditions.
- education and training – for a greater understanding of safety and health programs.
- program evaluation and improvement – monitoring program goals and identify opportunities for improvement.
- communication and coordination for employers on multi-employer worksites – encourages consideration on how how and safety actions affect safety of workers at the job site.
Recommendations or Requirements?
Although this publication includes a disclaimer that the practices are “recommendations only”, it is interesting that many OSHA construction (29 CFR 1926) standards require some of these core elements.
Consider, for example, OSHA’s 29 CFR 1926.20(b) – 1926.20(b)(2): it is “the responsibility of the employer to initiate and maintain” a safety program including “frequent and regular inspections of the jobsites, materials, and equipment.”
Furthermore, “competent persons” complete the inspections. OSHA 29 CFR 1926.32(f) defines a competent person as one “who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authority to take prompt corrective measures to eliminate them.”
In addition, OSHA 29 CFR 1926.21(b)(2) requires employers to “instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.”
As you can see, protection from falling, rooftop safety, and OSHA compliance includes a requirement to establish and implement an effective safety program. Furthermore, effective safety programs include training and inspections. In following OSHA recommended practices and regulations, the rooftop is a safer place.
Effective Protection from Falling
Because of the very nature of the risks involved in roofing work, effective fall protection measures are particularly important. There are various OSHA requirements for systems to provide protection from falling.
OSHA’s General Rule
OSHA’s 29 CFR 1926.501 includes a general rule. This general rule requires the use of guardrail systems, safety net systems, or personal fall arrest systems as protection from falling 6 feet or more to a lower level. A steep roof is one with a slope greater than 4 inches of vertical rise for every 12 inches of horizontal length. In roofing work involving steep roofs, the general rule is applicable, but also requires that a guardrail system have toeboards. See this post for more detail, What are toeboards and when to use them?
Low Sloped Roofs
What about low sloped roofs? A low-sloped roof has a slope less than or equal to 4 inches of vertical rise for every 12 inches horizontal length. OSHA 29 CFR 1926.501(b)(10) allows protection from falling via the use of guardrail systems, safety net systems, or personal fall arrest systems, but also allows more options. Additional options include
- a combination of a warning line system and guardrail system, safety net system, or personal fall arrest system, or
- warning line system and safety monitoring system, or
- for roofs 50 feet or less in width, the use of a safety monitoring system alone.
Protection from Falling below 6 Feet
Also, there are some situations in which there’s a need for rooftop safety equipment below 6 feet. Some include:
- OSHA 29 CFR 1926.501(b)(8)(i): When working less than 6 feet above dangerous equipment, workers need protection “from falling into or onto the dangerous equipment by guardrail systems or by equipment guards.”
- OSHA 29 CFR 1926.501(b)(9)(ii): Workers need fall protection (guardrail system, safety net system, or personal fall arrest system) when “reaching more than 10 inches below the level of the walking/working surface on which they are working.”
There are more OSHA fall protection requirements concerning the three conventional types of fall protection systems: guardrails, safety net systems and personal fall arrest systems. This post continues with a brief review of some OSHA requirements for guardrails.
Guardrail Fall Protection System
Guardrails provide a barrier to prevent falls. We have a variety of non-penetrating metal guardrails available for protection from falling. Here are some OSHA’s regulations for guardrails found in 29 CFR 1926.502(b):
- Guardrails must be 42 inches in height, plus or minus 3 inches.
- Guardrail systems must be able to withstand a force of 200 pounds or more within 2 inches of the top edge.
- Guardrails used around holes must be provided on all sides of that hole.
It is important to review OSHA fall protection requirements and rooftop safety training standards as well as to take advantage of OSHA’s free resources. The effort to do so will not only help to ensure compliance with OSHA roof safety but will also provide protection from falling. Thereby, keeping workers safe.