Kevin Lindley, Safety Consultant, FRSA Self Insurers Fund
In the November issue of Florida Roofing, we discussed Fall Safety Monitoring Systems. In this article, we continue the focus on fall protection safety and review Warning Line Systems.
In the OSHA regulations section 29 CFR 1926.501(b)(10) it states that for roofing work on low-slope roofs, “Each employee engaged in roofing activities on low-slope roof, with unprotected sides and edges 6 feet (1.8m) or more above lower levels shall be protected from falling by…or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system.” You will note that the warning line system is ALWAYS used in conjunction with another type of fall protection system. This is because there will be times when work is being performed beyond the warning line system. During these times, another type of fall protection is required in addition to the warning line. To fully understand the warning line system and how it 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.
As a reminder, 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)]. Finally, an unprotected side or edge is “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 39” tall or greater.
A. “The warning line shall be erected around all sides of the roof work area” [29 CFR 1926.502(f)(1)]. This clearly states the warning line shall surround the work area in the entirety of the work area, not just the side where work is ongoing closest to the edge. Think of this like a pen that designates the area where workers are permitted to walk freely without any other type of
fall protection in use beyond the barrier created by the warning line. Often, we see contractors only set-up a warning line on the perimeter edge they are working closest to, thus allowing their employees to roam freely on the remaining portion of the roof, including all areas where work may not be ongoing and leading edges associated with those areas. If the area you are working in does not have any leading edges, but there are leading edges anywhere else on the roof a worker could freely access, the leading edge must be protected. One option is to clearly define where work is ongoing and create a barrier with warning line at a point employees should not go beyond. In the eyes of OSHA, communicating the hazard to the workers in not enough: you must physically restrain them from critical hazards regardless of expense.
B. “When mechanical equipment is not being used, the warning line shall be erected not less that 6 feet (1.8m) from the roof edge” [29 CFR 1026.502(f)(1) (i)] and “When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1m) from the roof edge which is perpendicular to the direction of mechanical
equipment operation” [29 CFR 1926.502(f)(1)(iI)]. For simplicity, most roofing contractors tell their workers 6 feet away from the edge, unless mobile equipment is present, in which case the warning line should be set up 10 feet from the edge. The important thing to note is that the warning line CANNOT be seated or be any closer to the perimeter edge than 6 feet in any
location.
Consider interior corners of the roof, where a stanchion supporting the warning line must be set up so that the distance of the warning line does not get any closer to the leading edge or overhang the corner thus exposing the employee to the fall hazard. Many general contractors have adopted the requirement to maintain warning lines 10 feet from all leading edges.
OSHA’s requirements are a minimum and contractors have the right to exceed the OSHA requirements as long as the contractor is aware of the more stringent requirement they are required to follow. Maintaining a six foot distance from the edge is not possible in all locations, in which case you will be using the warning line system in conjunction with the guardrail system and be required to establish guardrails in all locations workers will be required to commonly encroach on the perimeter edge for safe passage. A common example of this would be where a roof is not very wide, mechanical units are present and the only means of travel along the roof would be to pass the unit on the leading-edge side, then warning lines would not be suitable in this situation. Another
example of a location guardrails may be required are building connections where the pathway is less than 15 feet in width. If employees are expected to pass, it is the contractor’s responsibility to provide workers with a safe workplace. Expecting a monitor to watch everyone pass through this type of condition all day is not acceptable.
C. “Points of access, materials handling areas, storage areas and hoisting areas shall be connected to the work area by an access path formed by two warning lines” [29 CFR 1926.502(f)(1)(iii)], often referred to as a controlled access zone,
which are clearly explained in 29 CFR 1926.502(g). Warning lines creating a hallway of sorts from the roof access ladder to the roof area enclosed by the warning line creates a specific location, outside the warning line, where no additional fall protection is required, and the walk area encroaches on the leading edge. If the project has a roof hatch or stair scaffolding which is located in a section of the roof where work is not ongoing and there are fall hazards present in or around that roof area, then the controlled access zone to the work area, which again should be barricaded off from the rest of the roof, will allow the work to be ongoing and provide safe access to the work area. Should the storage area be located outside the enclosed designated work area, a controlled
access zone shall be established from the work area to the storage area and the storage area shall be fully protected from fall hazards as well. The controlled access zone shall have a “gate” created by a warning line, chain, rope or other barricade from the enclosed work area warning line into the controlled access zone. Think of this like a house, the work area is a bedroom, the controlled access zone is a hallway. There must be a barrier (like the bedroom door) leading into the hallway or controlled access zone and the bedroom door must always be closed when not in use for passage.
D. “The rope, wire or chain shall be flagged at not more than 6-foot (1.8m) intervals with high-visible material” [29 CFR 1926.502(f)(2)(i)]. Flags move, get torn and are non-existent at ends of premanufactured roof warning line. Warning lines and flags fade in the sun and weather. If the project duration is longer than the lifetime of the warning line, warning lines must be
replaced. If flagging is missing, faded or anything else resulting in a space between warning line flags greater than 6 feet, flagging must be added.
E. “The rope, wire or chain shall be rigged and supported in such a way that its lowest point (including sag) is no less than 34-inches (1.0m) from the walking/working surface” [29 CFR 1926.502(f)(2)(ii)]. Safety traffic cones typically are 18-inches, 28-inches and 36-inches in height. Not only do they not typically meet the height requirement, they also do not meet the requirement stated in 29 CFR 1926.502(f)(2)(iii) stating they must also resist a 16 pound (71N) applied horizontal force in the direction toward the roof edge. It should also be noted that there are traffic cones, such as the one pictured, that, although they
do meet the height requirement, the base does not provide adequate support to meet the tip-over resistance. On a related note, even designated, premanufactured roof fall protection warning line stanchions that have a rectangular rubber base are required to
be set-up in a specific orientation to the leading edge of the roof so that they too meet the tip-over resistance requirement. On the rubber base, there is often engrained a note which reads “EDGE” with a line either over or under the word. The designation is that the line should be set parallel with the leading edge of the roof.
F. “The rope, wire or chain shall have a minimum tensile strength of 500 pounds (2.22Kn) and after being attached to the stanchions, shall be capable of supporting, without breaking, the loads applied to the stanchions as prescribed in paragraph (f)(2)(iii) of this section” [29 CFR 1926.502(f)(2)(iv)]. Caution tape does not meet the strength requirement of a
warning line. Most premanufactured roof warning lines consist of a rope encased in a plastic sleeve and triangular shaped flags that are either yellow or red in color. And although RED Warning line is more appropriate because RED is designated for DANGER while YELLOW is typically an indicator of CAUTION – and we are talking about a POTENTIALLY SERIOUS FALL INJURY AREA, either color is acceptable. Neither color of plastic warning line will outlast the other. Some contractors have chosen to use systems made with steel cable and metal painted flagging, where the rope meets the breaking strength standard and caution tape is inserted into the rope at six-foot intervals.
G. “The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over” [29 CFR 1926.502(f)(2)(v)]. Typically, roofers take the warning line, pass it through the opening of the stanchion then continue onto the next stanchion and do the same until the line is entirely used and tied to a stanchion on either end. The problem with this is that the line is not connected to the stanchion, it merely passes through the stanchion. The quick fix: twist each stanchion in place 180 or 360 degrees, thus locking the warning line to the individual stanchions. It is only one more step and since the line is up, let’s
do it correctly. Another option is to pull the warning line through the small hole at the top of the stanchion, insert a screw or other small rod into the warning line and pull the line back so that the screw or rod is held tight against the stanchion by the warning line. This last method can also be used to add a stanchion to an existing warning line system should you find the warning line is too low in one location and workers are unable to maintain the minimum height above the walking/working surface.
H. “No employee shall be allowed in the area between a roof edge and warning line unless the employee is performing roofing work in that area” [29 CFR 926.502(f)(3]. When work is conducted outside the warning line system, another form of fall protection must be utilized by the worker(s) who are working between the roof edge and the warning line system. As previously stated, workers must utilize personal fall arrest system, guardrail system, safety net system or safety (fall) monitor system. Unsupervised or unprotected access beyond the warning line system has resulted in OSHA penalties, sever injuries and deaths for too many employers whose employees stated they were just going to be doing an activity for a brief period and did not think they needed additional fall protection at the time. No activity is too brief to avoid the requirement for additional fall protection.
I. Warning lines are not permitted to be used around openings in the roof, they are only permitted as fall protection at leading edges. Opening(s) are defined as “a gap or void 30 inches (76cm) or higher and 18 inches (48cm) or wider in a wall or partition, through which employees can fall to a lower level. “Each employee on a walking/working surface shall be protected from falling through holes (including skylights) more than 6 feet (1.8m) above lower levels, by personal fall arrest systems, covers or guardrail systems erected around such holes” [29 CFR 1926.501(a)(4)(i)]. Warning lines erected around holes in the roof simply are not permitted.
J. “During the performance of roofing work, material and equipment shall not be stored within 6 feet (1.8m) of a roof edge unless guardrails are erected at the edge” [29 CFR 1926.503(j)(7)(i)]. Furthermore, when workers are working outside the warning line, it is recommended that limited materials, tools and equipment be taken with them outside the warning line and that debris created be removed. Debris created from projects should also be stored a minimum of 10 feet from leading edges as they have a high potential of being blown and falling from the elevated walking/working surface.
Now that you have an understanding of a warning line system, you may be wondering how this system gets established in the first place. The warning line system does not magically appear on the site when workers get there to do the work. Installing the fall
protection system must be the first agenda item on the project and its removal the last. While the warning line system is being established or taken down, the workers handling the task shall use the fall monitor system.
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 workers in the field. Train all workers on the types 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 (FRSA-SIF) has Professional Safety Consultants throughout the state who are willing to provide SIF members with fall protection training as required by OSHA at no additional cost. Find out how your company can apply for workers’
compensation insurance coverage with the FRSA Self Insurers Fund by contacting us at 800-767-3772, ext. 206 or visit our website at www.frsasif.com.
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