Kevin Lindley, Safety Consultant, FRSA Self Insurer's Fund
In the OSHA regulations section 29 CFR 1926.501(b) (10) it states that for roofing work on low-slope roofs “on roofs 50-feet (15.25m) or less in width (see Appendix A to subpart M of this part), the use of a safety monitoring system alone [i.e. without the warning line system] is permitted.” This one fall protection system, which is permitted to be used by roofing contractors for roofing work on low-slope roofs ONLY, has become the primary type of fall protection utilized by residential roofing contractors. The guidelines stated by OSHA for use of the Safety Monitoring System however are often unknown, ignored or simply forgotten. Let’s break down the requirements for proper use of the Fall Safety Monitoring System to ensure it is being used properly and company liability in the eyes of OSHA is not present.
Roofing work is defined as “hoisting, storage, application and removal of roofing materials and equipment including related insulation, sheet metal and vapor barrier work, but not including the construction of the roof deck [29 CFR 1926.501(b)].” You will note that wood blocking, fascia, nor perimeter nailers are noted as these are considered by OSHA to be “carpentry work,” not roofing work. Furthermore, roof substrate deck replacement or installation are also not considered to be “roofing work,” meaning that if workers are engaging in wood installation in any capacity, they are not permitted to utilize the Fall Safety Monitoring
System. The second part of this requirement is work on low-slope roofs. A low-slope roof is defined as “a roof having a slope less than or equal to 4 in 12 (vertical to horizontal)” [29 CFR 1926.501(b)]. Yes, OSHA compliance officers will verify the slope of the deck and not take the workers word for it when they say everything is 4:12.
A. “The Safety Monitor shall be a competent person who is designated by the employer and able to recognize fall hazards [29 CFR 1926.502(h)(1)(i)].” Simple, pick an employee and make him the monitor – WRONG! Competent Person is defined 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 authorization to take prompt
corrective measures to eliminate them [29 CFR 1926.32(f)].” Competency is either obtained through training or experience, both of which are expected to be proven in documentation should they be required or requested. The second underlying portion of this provision is that the individual(s) must be “designated by the employer.” Not just any worker can be given the responsibility or title of roof monitor. A good recommendation to follow, which is often required on larger projects by general contractors, is to have a site-specific competent person form or document indicating who the designated monitor(s) is on the project. It is always recommended to have more than one designated available monitor on every job. Although it is not required, it is also recommended to have the monitor wear a safety vest or other indicator as to who the monitor is on the roof.
B. “The Safety Monitor shall warn the employee when it appears that the employee is unaware of a fall hazard or is acting in an unsafe manner [29 CFR 1026.502(h)(1)(ii)]” and “The Safety Monitor shall be close enough to communicate orally with the employee [29 CFR 1926.502(h)(1)(iv)].” These provisions are each stating the same thing: the worker who is
designated as the Safety Monitor needs to be within vocal distance of all workers he or she is monitoring and be able to actively monitor all workers closely enough to observe if it appears that they are not aware of the hazard. Active communication is key, a monitor who is silent and assuming workers are aware of all hazards they are monitoring is ineffective.
C. “The Safety Monitor shall be on the same walking/working surface and within visual sighting distance of the employee(s) being monitored [29 CFR 1926.502(h)(1)(iii)].” In a way this is stating the same thing as the previously noted provision, however it is also stating that the monitor must be on the same level as those being watched. The monitor cannot be on
the ground watching the workers on the roof, nor can they be on an upper level watching the workers from above. The monitor must be present yet not exposed to the fall hazard themselves.
D. “The Safety Monitor shall not have other responsibilities which could take the monitor’s attention from the monitoring function [29 CFR 1926.502(h)(1)(v)].” The monitor cannot work, be on the phone, be absent, be operating equipment or tools. The monitor is solely a monitor there to watch the others work. Sounds like the best job on the roof, however it gets tiresome, boring and many monitors begin to feel as though (or get told) they are not contributing to the efforts of the crew while monitoring.
As of January 15, 2021, OSHA violations carry a penalty of up to $13,653 per violation. A Willful or Repeated violation can result in up to $136,532 per violation. Considering that a fall protection violation often results in multiple citations and fall protection issues can be enforced per employee exposed to the fall hazard separately, the designated Fall Safety Monitor has a very important roll. The ability of roofing contractors to utilize this system not only relieves frustration in the field from the use of personal fall arrest system ropes and harnesses, but also increases production. However, this system also has a much higher potential for a fall and liability for the company. It is recommended to use this system as a last resort. In 2018, $5.9 billion was paid in compensation costs for falls from elevations, however the true cost must also take into account the indirect cost and the costs of an OSHA penalty. Calculations made by the National Safety Council estimated that a fatality at work costs approximately $1,120,000 not including the value of the loss of a loved one, which cannot be calculated.
Workers on roof slopes less than or equal to 4:12 are required to use one of the following for fall protection per OSHA standards:
■ Safety Nets
■ Guardrail Systems
■ Personal Fall Arrest Systems
■ Warning Line Systems in conjunction with either
Personal Fall Arrest Systems or Fall Safety Monitoring System and only on roofs 50’-0” or less in width – The Fall Safety Monitoring System alone.
When considering the type of fall protection system to be used on your next project, consider not only the cost of the system, but the functionality of the system and the protection benefits provided to the workers in the field. We need every worker we have,
every day and want them to go home to their families the way they left for work in the morning.