Kevin Lindley, Safety Consultant, FRSA Self Insurers Fund
Per OSHA regulations, section 29 CFR 1926.501(b)(1), there are only three types of conventional fall protection systems that are acceptable for use by any trade, in any leading-edge environment. Those three types of fall protection are 1. guardrail systems, 2. safety net systems or 3. personal fall arrest systems. For this article we are going to focus solely on the guardrail systems, the requirements for set-up, maintenance and use in the field. The need and use of guardrail systems are obvious because the guardrail system creates a safe work area in which the fall hazard is protected and provides the worker with the greatest amount of safe work zone area to operate. To fully understand the guardrail systems and how they should be set-up and function we need to break down where the system can be used, what the limitations are and what makes up the entire system.
An unprotected side or edge is defined as “any side or edge (except at entrances to points of access) of a walking/working surface, e.g., floor, roof ramp or runway where there is no wall or guardrail system at least 39 inches (1.0m) high.” The width of the parapet is not taken into consideration – ever. To qualify, parapet walls must be 39inches tall or higher. This definition applies to all construction trades, not only for roofing work. 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 1926.500(b)]. Guardrail systems are permitted to be used on any surface, regardless of the slope of the walking/working surface. As referenced in 29 CFR 1926.501(b)(11), when roofing on steep-slope roofs, only the three systems noted previously are permitted systems to be used. A steep-slope roof is defined as “a roof having a slope greater than 4-in-12 (vertical to horizontal).”
A. “The top edge height of top rails or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) above the walking/ working surface” [29 CFR 1926.502(b)(1)]. It should be noted that the height of the guardrail system is the first requirement OSHA notes about the system, not the materials it must be made of, nor the forces it must be able to resist. Despite the height being a very important factor of the guardrail system, it often varies dependent upon the circumstances of the work for which the guardrail is providing fall protection. For instance, if a worker needs to utilize a ladder or stilts within close proximity of the guardrail system, the guardrail top railing height must be adjusted to maintain the 42-inch height above the workers “working surface” ladder height or stilt height. Otherwise, the worker must utilize an additional type of fall protection while on the ladder or stilts, such as a personal fall arrest system. The height must also be taken into consideration when located within close proximity to working surface elevation changes. For example, if there is a roof deck that has a change in elevation along the edge of anything greater than 6 inches, the top rail height must be added (an additional top rail above the normal top rail) to within 6 inches on the lower working surface leading up to the step-up of the other working level. The standard rail would provide adequate fall protection for the lower deck, while the additional top rail would provide adequate fall protection
for workers on the upper deck.
B. “Midrails, screens, mesh, intermediate structural vertical members or equivalent intermediate structural members shall be installed between the top edge of the guardrail system and the walking/working surface where there is no wall or parapet wall at least 21 inches (53 cm) high” [29 CFR 1926.502(b) (2)]. A top railing is not enough to suffice as fall protection alone, there must be a system in place beneath the top railing to provide additional fall protection. Screens, mesh or any component other than a midrail running horizontal to the walking working surface, shall not leave a gap or opening greater than 19 inches in width and is required to completely cover the opening from the top rail down to the walking/working surface.
C. “A standard toeboard shall be 4 inches nominal in vertical height from its top edge to the level of the floor, platform, runway or ramp. It shall be securely fastened in place and with not more than 1/4-inch clearance above the floor level. It may be made of any substantial material either solid or with openings not over 1 inch in greatest dimension” [29 CFR 1910.23(E)(4)]. You may notice that the OSHA standard for toe board requirements is not listed in 1926 (construction standards), despite being required in the 1926.502(b)(11) for steep-slope roof surfaces. Toe boards are not considered an integral part of a guardrail for fall protection purposes on low slope leading edges UNLESS there is an essential need for protection of falling materials, equipment or debris beneath the area where a guardrail system is located. Best work practices are to install toe boards in conjunction with a guardrail system, including stair scaffolding landings, where workers below could be exposed to an overhead hazard.
D. “All openings greater than 12 inches by 12 inches will have perimeter guarding or covering [29 CFR 1926 Subpart M Appendix E, Holes]. When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of the hole.” [29 CFR 1926.502(b)(11)]. It is important to note that warning line systems are not permitted to be used around a
hole in the walking/working surface. There are additional provisions for holes in the walking/working surface used for access in 1926.502(b)(13) so that the guardrail can be equipped with a gate or offset that a person cannot walk directly into the hole. The hole must always be completely protected on all sides, regardless of the location of the work in progress.
E. “Guardrail systems shall be capable of withstanding, without failure a force of at least 200 pounds (890 N) applied within 1 inch (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge” [29 CFR 1926.502(b)(3)]. OSHA has provided specifications for most commonly used materials that will meet the requirements in Subpart M Appendix B. As previously noted, there are many types of guardrail systems available by many reputable manufacturers, all of whom have tested their systems to meet the OSHA requirements for fall protection.
F. “The ends of all top rails and midrails shall not overhang the terminal posts, except where such overhang does not constitute a projection hazard” [29 CFR 1926.502(B)(7)]. Although it may be acceptable to have rails overlap one another at exterior corners, it is prohibited to have them overhang at interior corners or where workers have access to the exterior side of the structure where the guardrails are set-up.
G. “When guardrail systems are used at hoisting areas, a chain, gate or removeable guardrail section shall be placed across the access opening between guardrail sections when hoisting operations are not taking place” [29 CFR 1926.502(b)(10)]. It is important to note that while the guardrail system is taken down for hoisting operations, employees in that area are no longer protected by a guardrail fall protection system, therefore they must utilize another form of fall protection such as personal fall arrest. It is also very important that employees who remove sections of the guardrail for hoisting operations, fully replace the guardrail system and secure them in place when the hoisting activity has been completed.
H. “Top rails and midrails shall be at least 1/4-inch (.06 cm) nominal diameter or thickness to prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-foot (1.8 m) intervals with high-visibility material” [29 CFR 1926.502(b)(9)]. Beyond the importance of the thickness of material to be used, it is also noted that when wire rope is used, flagging must be present similar to that of a warning line system. The wire rope obviously has a much higher tensile strength than the materials permitted for a warning line system and are also designed so that they are capable of withstanding outward forces with minimal deflection as noted previously.
Now that you have an understanding of a guardrail system, you may be wondering how this system is installed in the first place. The guardrail system does not magically appear on the site when workers get there to work. The fall protection system must be the first agenda item on the project and removal shall be the last agenda item. While the system is being established or taken down, the workers handling the task shall use the Fall Monitor System. System manufacturer guidelines shall always be referenced and followed and by no means are contractors permitted to alter components of a guardrail system.
As of January 15, 2022, OSHA violations carry a penalty of up to $14,502 per violation. A Willful or Repeated violation can result in up to $145,027 per violation. A fall protection violation often results in multiple citations and fall protection issues and can be enforced per employee exposed to the fall hazard individually, so the correct materials, set-up, maintenance and following the rules during operations is vital. 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, it also increases productivity and allows a greater area of work to be performed or easier passage in tight locations. However, this system has a high potential for workers to remove components,
leave individual parts not fully attached and push the system beyond its limits, resulting in severe injury or death. When this system is being used on a roof, all workers in the area shall be trained on the proper set-up, use and restrictions of the system. A fall from an elevation of 6 feet or greater is a serious incident roofers should avoid at all costs. In 2018, $5.9 billion was paid in compensation cost for falls from elevations, however the actual cost must also consider the indirect cost and the costs of an OSHA penalty. Calculations made by the National Safety Council estimated that fatalities at work cost $1,120,000, not including the value of loss of life or a loved one which cannot be calculated.
Workers exposed to a fall potential of 6 feet or greater are required to use one of the following for fall protection per OSHA standards: safety nets, guardrail systems or personal fall arrest systems. 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. Train all workers on the type(s) of fall protection systems being used on the project so that they understand how it should appear, how it works and what their role in the system is. 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.
The FRSA Self Insurers Fund (SIF) has professional safety consultants throughout the state of Florida who are willing to provide SIF members with fall protection training as required by OSHA at no additional cost. Not an SIF member? Call today to apply at 800-767-3772 ext. 206 or visit our website at www.frsasif.com.
Next Article