FRSA-SIF Safety
Falls are the leading cause of death in the construction industry. According to OSHA, out of 991 construction fatalities in 2016, 370 were the result of falls to a lower level. Many falls can be avoided by implementing and enforcing a good fall protection program. Your fall protection program should outline inspections of the roof deck, fall prevention, fall protection, engineering controls and fall protection equipment, which are the primary means of eliminating injury and death from falls. In this article, we will be covering fall protection options for the roofing industry.
The first part of the fall protection standard states that an employer must 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 for roofing contractors 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 some type of roof inspection protocol system which documents the integrity of the roof prior to any 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 sloped roofing (4:12 and below) or steep sloped roofing (4:12 and above). Along with conventional fall protection, there are also other fall protection options for roofing contractors that work on low-slope roofs. We’ll explain what type of fall protection is required for steep roofs and alternative fall protection permitted for low-slope roofs.
Warnings – Always read all instructions and warnings contained on the product and packaging before using any fall protection equipment.
Inspection – All fall protection equipment must be inspected prior to each use and written documentation should be performed by a competent person on a quarterly basis.
Regulations – Understand all Federal, State, Local and Provincial regulations pertaining to fall protection before selecting and using the equipment.
Product/System Preferences – If there are any doubts about which fall protection products to use, contact your product distributor or manufacturer directly.
System Components – Only components that are fully compatible with one another should be used. Fall arrest systems are designed and tested as complete systems and should be used in this way.
Rescue Planning – Minimizing the time between a fall occurrence and medical attention of the worker is vitally important. A thorough rescue program should be established prior to using fall protection equipment.
What to Do After a Fall – After a fall occurs, all components of the fall arrest system should be removed from service.
Conventional fall protection can be used for either low-slope or steep roofs. However, it is the only option when working on steep 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). Midrails, when used, 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 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, of 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 standards state that an employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed to minimize these hazards. Training should be documented and provide information on regulations, potential hazards, equipment selection and instruction on how to use the equipment correctly.
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 ONLY with a safety monitor 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 6 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 6 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 are using PFAS.
Companies must identify fall hazards and implement effective fall prevention programs and fall protection systems to protect employees. The primary goal is to eliminate fall hazards. In construction, when an employee is working at a height of six feet or more, the employee is risking a fatal fall: fall protection and fall prevention programs are required. Using fall prevention and fall protection engineering controls and fall protection equipment are the primary means of eliminating injury and death from falls.
For more details on fall protection or for OSHA compliance, contact your local Safety Consultant or visit the OSHA website at www.osha.gov.
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