Brad Mang, FRSA Self Insurer’s Fund Safety Consultant
Each year, falls to a lower level are the leading cause of death among construction workers and account for one third of all construction fatalities. According to the latest report from the Bureau of Labor Statistics annual Census of Fatal Occupational Injuries Summary, fatal injuries for roofing contractors in 2022 reported 124 deaths, an increase from 115 in 2021. This alarming increase in fatalities has also placed roofing as the second most dangerous job in the U.S., right behind the logging industry. Along with this troubling data, OSHA released their Top 10 Violations for 2023 which included, at number one, Fall Protection, General requirements (7,271 citations issued) and again on the list at number 8, Fall Protection, Training requirements (2,112 citations issued).
The key to help combat this increase in fatality rates is for roofing contractors to develop a company program that enables each employee to be able to recognize the hazards of falling. Each employee should be trained in the procedures to be followed to minimize these hazards and conduct inspections to ensure employees are compliant with the program. The following is a brief description of the types of conventional fall protection OSHA requires on roofing jobsites.
The first part of the fall protection standard states that an employer must first determine “If the walking/working surfaces on which its employees are to work have the strength and structural integrity to support the employee safely.” This is an extremely important
standard to address since there has been an increase in employee deaths related to roof failures over the last couple of years. A roofing contractor should create a roof inspection protocol which documents the integrity of the roof prior to work commencing.
In construction, OSHA requires that any employee working six feet or more above lower levels have some type of fall protection. Since OSHA removed the directive for residential fall protection back in 2011, they now look at all roofing projects, whether they are residential or commercial, either as low-slope roofing (4:12 and below) or steep-slope roofing (4:12 and above). Along with conventional fall protection, there are also other options for roofing contractors that work on low-slope roofs. I’ll explain what type of fall protection is required for steep roofs and alternative fall protection permitted for low-slope roofs.
Conventional fall protection can be used for low-slope roofs, however, it is the only option when working on steep-slope roofs. Conventional fall protection consists of three types of fall protection:
The first option is a safety net. Although not very common in roofing, a safety net can be used for fall protection. If used, a safety net must be installed as close as possible under the walking/working surface on which employees are present but never more than
30 feet below such levels. Safety nets shall be installed with enough clearance under them to prevent contact with the surface or structures below when subjected to an impact force.
The second option is guardrail systems. This system is more commonly used on commercial structures but is acceptable on residential buildings as well. When using guardrails, the top rail shall be 42 inches plus or minus 3 inches above the walking/working level. Midrails, screens, mesh, intermediate vertical members or equivalent intermediate structural members shall be installed between the top edge of the guardrail system and the walking/working surface (when there is no wall or parapet wall at least 21 inches high). When used, midrails shall be installed at a height midway between the top edge of the guardrail system and the walking/working level. Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds in any outward or downward direction.
The third and most common conventional fall protection is the personal fall arrest system (PFAS). Personal fall arrest systems consist of a full body harness, a lifeline, a lanyard and an anchor. D-rings and snap hooks shall be corrosion resistant, have a smooth surface and have a minimal tensile strength of 5,000 pounds. Only locking (double action) snap hooks shall be used. Lanyards and lifelines shall have a minimum breaking strength of 5,000 pounds. Anchors used for attachment of personal fall arrest equipment shall be capable of supporting at least 5,000 pounds per employee.
OSHA fall protection standards also provide additional options for fall protection on low-slope roofs. Roofing contractors can use a warning line system with a designated safety monitor for roofing projects over 50 feet in width and are allowed a safety monitor only if the roof deck is less than 50 feet in width.
The safety monitor shall be a competent person that recognizes fall hazards and warns employees when it appears that the employee is unaware of a fall hazard or is acting in an unsafe manner. The safety monitor shall be on the same working level, within sight distance and shall not have any other responsibilities that could take his/her attention from the monitoring function.
A warning line system cannot be used alone. When used, the warning line system shall be erected around all unprotected sides of the roof work area at least six feet from the edge. If mechanical equipment is used, the line shall be at least 10 feet from the edge, perpendicular to machine travel. A warning line system must be flagged a minimum of every six feet with high visibility material and have a semi-rigid height of 34-39 inches. The line shall resist, without tipping over, a force of at least 16 pounds and have a tensile strength of at least 500 pounds. No employee shall be allowed in the area between a roof edge and a warning line unless they are performing roof work and are monitored or they are using PFAS.
This is a basic guide for fall protection in construction and alternative forms of fall protection for roofing contractors working on low-slope roofs. For more details on fall protection or for OSHA compliance, contact your local FRSA-SIFSafety Consultant or visit the
OSHA website at www.osha.gov.
Previous Article