When most people think about rooftop fall protection, they think about the edge. That makes sense. The leading edge is visible, obvious, and dangerous. But according to Dan Huntington, General Manager at Kee Safety and a fall protection expert with more than a decade of hands-on rooftop safety experience, the edge is not always the first-place safety teams should look. In a recent OHS webinar, Dan explained that effective rooftop safety starts by understanding how workers actually access, move across, and work on the roof.
“This is all about taking knowledge and principles and then applying them in the real world,” Dan said. That practical approach matters because rooftop fall hazards are not always where people expect them to be. In many cases, the most frequently encountered hazard is not the roof edge. It is the access point.
After access points, skylights are often the next major rooftop blind spot. They may not look dangerous from a distance. Many are translucent, weathered, or visually blended into the roof surface. But OSHA 1910.28 (b) (3) specifically includes skylights in its fall protection requirements for holes, stating that employees must be protected from falling through any hole, including skylights, that is 4 feet or more above a lower level. Acceptable options include covers, guardrail systems, travel restraint systems, or personal fall arrest systems.
Dan was direct about the risk. “You are more likely to fall through a roof than off a roof.” That line makes the issue easy to understand. Skylights are not just daylighting features. On a rooftop, they are a potential fall-through hazard. This is especially important in snowy climates, where skylights can become hidden under accumulation. A worker removing snow, inspecting equipment, or crossing the roof may not see the skylight at all until it is too late.
Kee Safety solutions like Kee Cover skylight screens and Kee Dome skylight railing are designed to help protect workers from these types of fall-through hazards while preserving the roof surface. Kee Cover offers non-penetrating skylight screen options, and Kee Dome creates a non-penetrating railing barrier around skylights.
The roof edge is still a critical part of any rooftop safety program; but Dan’s method places it in context. Once the access points and skylights are understood, the next step is to look at where work is happening in relation to the edge. OSHA’s low-slope roof requirements use distance-based zones. Work performed less than 6 feet from the roof edge requires protection such as guardrails, safety nets, travel restraint, or personal fall arrest. Work performed at least 6 feet but less than 15 feet from the edge requires similar protection, although a designated area may be used when the work is both infrequent and temporary. At 15 feet or more, OSHA allows more flexibility if the work is infrequent and temporary and an enforced work rule keeps employees away from the edge.
Dan summarized the risk in simple terms. “The closer I get to the roof edge, the higher the likelihood of a fall is to occur.” That is why distance matters. A small slip, trip, or misstep near the edge can quickly become a serious or fatal incident. For many rooftops, non-penetrating guardrail systems like Kee Guard provides a collective form of protection that does not rely on workers tying off correctly every time. Kee Guard is designed as a modular, free-standing rooftop guardrail system that is not fixed directly into the roof membrane.
One of Dan’s strongest points was that fall protection should not only be about meeting a code requirement. It should be about designing a rooftop environment where safe movement is the easiest movement.
That means looking at the full path of travel.
• How do workers access the roof?
• Where do they walk once they are on the roof?
• Are skylights protected?
• Is rooftop equipment too close to the edge?
• Are warning lines, guardrails, gates, or covers being used correctly?
• Is the system practical enough that workers will actually follow it?
Dan cautioned against safety measures that create new hazards or depend too heavily on perfect behavior. “If your safety introduces a hazard, it’s not a good safety.” That is why passive and collective fall protection solutions are often preferred where practical. Guardrails, gates, skylight screens, and designated traffic paths help protect everyone on the roof without requiring each worker to make the right decision every time.
A strong rooftop safety program starts with exposure. The most serious hazard is not always the most obvious one. The best place to start is often the place workers use the most. For facility managers, EHS professionals, maintenance teams, and building owners, Dan’s message is simple: walk the roof, understand the traffic patterns, and look at hazards in the order workers encounter them.
As Dan told the webinar audience, “If we apply it correctly, we will save lives.”
Source note: Article built from Dan Huntington’s OHS webinar and direct quotes provided.
Dan Huntington is a fall protection expert with over 10 years of hands-on experience helping companies protect workers at height. He specializes in OSHA compliance, risk assessments, and developing rooftop safety programs. Dan doesn’t just teach theory he’s regularly on rooftops identifying hazards and delivering practical, effective solutions. Formally trained in OSHA standards and risk assessment, Dan has presented at national safety events including the ASSP Expo and the Western States Roofing Expo. He leads Kee Safety’s rooftop safety experts across North America, helping organizations assess hazards and implement life-saving solutions.
Website: https://www.keesafety.com/
Email: info@keesafety.com
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