When we meet with clients whether they’re a facilities manager or a safety manager, and responsible for a commercial roof, maybe multiple commercial roofs, we repeatably see some of the same common rooftop hazards. Imagine we're sitting at a board room table together and you've brought me out as a fall protection expert to advise on where we need to protect to get started on this rooftop fall protection journey to create a safe work at heights environment at your facility.
In nine times out of ten, you're going to say we have an HVAC unit near the roof edge. I really need to protect that unit. I think this is our number one rooftop hazard and I want you to go measure it tell us what our options are. I would say absolutely, I agree with you 100%. We need to do that, but before we do that, I need to understand how we're going to get on to the roof in the first place. I need to understand the access points.
OSHA has very clear regulations on how we protect access points, those first hazards, the initial hazard that we see when we go up to assess the roof or when you go up to work on the roof. I want to point out that the codes we’re talking about are from 1910. That means that we're referring to general industry fall protection codes. These codes apply to the building after it's been built, so it doesn't apply during the construction process of the building.
OSHA Code Addressing Hazard: 1910.28(b)(3)(iv)
"Each employee is protected from falling into a ladderway floor hole or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset must be used."
OSHA Compliant Solution: Kee Hatch
So now that you’ve thought about accessing your roof and making sure access points are protected, we're back to thinking again about the other roof hazards. We've talked about the access points. You’re probably thinking, yeah, yeah, Dan, you've convinced me I need to protect my access points, but I've got a HVAC unit near the edge. I want you to protect the leading edge. Can't we just talk about the leading edge now? And I say no. We have one more hazard that we need to talk about.
The second hazard we need to talk about is the skylights on your roof. Unprotected skylights are a major fall hazard. OSHA considers skylights holes and statistically speaking, you are more likely to fall through your roof than off your roof. I think there's a few reasons for that. I think number one is actually ignorance. We don't recognize that skylights are holes. A lot of them are translucent. You don't see the fall when you're looking at the skylight, you don't feel it on the back of your neck, that fear of falling. Many people think that their skylight is fall rated, the truth is they probably aren't.
OSHA Code Addressing Hazard: 1910.28(b)(3)(i)
"Each employee is protected from falling through any hole (including skylights) that is 4 feet (1.2 m) or more above a lower level by one or more of the following:
• Covers
• Guardrail Systems
• Travel Restraint Systems; or
• Personal Fall Arrest System"
OSHA Compliant Solution: Kee Cover
Skylights are typically not made out of glass, they're made out of plastic. So that plastic ends up sitting outside in the sun all day, every day, all year for 3 to 5 years. However long that skylight's been there. And what happens to that plastic over time is through UV degradation. The sun breaks down the strength of the polymers and that plastic becomes very, very brittle. The easiest way for me to describe this to you is, picture this summer, you're at the family barbecue and the seat that you get to sit in outside is the cheap white plastic chair that's been sitting outside for the last three seasons. You're looking at it like, I don't know if it's gonna hold me. You sit down on it anyways and the thing just disintegrates, the same thing happens to skylights on roofs.
Now, conveniently, manufacturers put a sticker on the side of the skylight that says risk of fall. Inconveniently the plastic of the skylight starts to fade and that sticker starts to disappear, right around the time the skylight is becoming very brittle. So right around the time the sky is becoming a very dangerous potential hazard is the time that our fading sticker telling us that it's a potential hazard disappears completely. So if you have a skylight protect it.
The most immediately apparent danger on any rooftop is the edge—this is why so many safety managers prioritize it for safety measures. The closer someone works to this edge, the greater the risk of an accident. According to OSHA regulations, any task performed within 15 feet of an open roof edge necessitates protective measures for each worker. This could mean installing a guardrail system or deploying another approved form of safety equipment.
OSHA Code Addressing Hazard: 1910.28(b)(13)
"(i) When work is performed less than 6 feet from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system.
(ii) When work is performed at least 6 feet but less than 15 feet from the roof edge, the employer must ensure each employee is protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. The employer may use a designated area when performing work that is both infrequent and temporary.
(iii) When work is performed 15 feet or more from the roof edge, the employer must:
(A) Protect each employee from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system or a designated area. The employer is not required to provide any fall protection, provided the work is both infrequent and temporary; and (B) Implement and enforce a work rule prohibiting employees from going within 15 feet (4.6 m) of the roof edge without using fall protection in accordance with paragraphs (b)(13)(i) and (ii) of this section."
OSHA Compliant Solution: Kee Guard
Not sure where to start when thinking about the fall hazards on your rooftop? We provide complimentary rooftop safety audits. Contact Kee Safety today. We have fall protection experts that are available nationwide to help you understand the hazards and offer the best possible solution. We analyze your rooftop traffic, the duration and frequency of the work that's being done on your rooftop and provide customized safety solutions.
About the Author
Daniel Huntington is an experienced sales and technical product trainer with a demonstrated history of working in the Fall Protection Industry. As a Fall Protection Industry Expert, he is formally trained in OSHA fall protection standards and risk assessment. He is a respected compliance educator and trainer in rooftop safety, presenting at the 2019 ASSP Expo for the International Society of Fall Protection (ISFP) where he facilitated a course on improving safety for people working at height.
Website: https://www.keesafety.com/
Email: info@keesafety.com
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