Brad Mang, Safety and Loss Control Consultant, FRSA-SIF
As a safety consultant, there is not a day that goes by that I don’t speak to a roofing contractor about fall protection. During these conversations, I have found that many times we are only focused on protecting employees from falling from the edge of the roof deck and not discussing the possibility of falling through the deck.
Per the latest data from the Bureau of Labor Statistics, there has been a significant rise in deaths and injuries related to falls from collapsing structures and falls through openings of roof decks. We at the FRSA Self Insurers Fund can attest to this first hand and
have developed a deck inspection protocol program for our accounts to implement into their company safety manuals.
The following information is a guide for all contractors to use in developing their own deck inspection program to help prevent falls.
OSHA has no set standard for employers to follow regarding developing a deck inspection program, but they do state in OSHA standard 1928.501(a)(2) “The employer shall determine if the walking/working surfaces on which employees are to work have the strength and structural integrity to support employees safely. Employees shall be allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity.”
First and foremost, all employees exposed to a roof deck should be involved in the development of the roof specific inspection program. The purpose of the program is to identify the hazards associated with replacing or repairing each particular roofing system prior to and during normal operations. Employees will need to be able to identify the many different types of roof decks such as plywood, steel deck, lightweight and structural concrete, Tectum and gypsum board. All employees performing a deck inspection will need to be trained to understand the difference in the components mentioned, prior to any inspection or roofing work being performed. Employees will also need training to consider other hazards such as but not limited to: skylights, existing roof penetrations, electrical hazards, trip hazards and accessibility to the roof deck.
Initial Inspection (Pre-Bid or Prior Contract) It should be assumed that any re-roof project means that the existing roof has deteriorated and the potential for failure exists. The company representative will need to gather the following information, to the best of their ability, to identify any possible defects in the deck.
■ Age of existing structure and building
■ Types of material currently installed
■ Structural support of the roof deck
■ Identify current leaks
■ Identify prior repairs
■ Number of roof penetrations
■ Equipment mounted on roof deck
■ Photos of top and bottom of roof deck
■ Knowledge from the building owner of any structural concerns
■ Any other information the company deems necessary.
Prior to any work commencing the company project manager, superintendent, and/or foreman shall perform an additional hazard assessment to determine the safety requirements of the job. During this meeting, another inspection of the roof deck shall be performed and management will discuss the information gathered during the initial inspection. The following items should be re-addressed during this meeting:
■ Top and bottom of roof deck inspected for structural integrity
■ Identify additional signs of defects not previously noted during initial inspection
■ Verify hazards associated with electrical supplies to the roof deck
■ Verify equipment installed on the roof deck
■ Potential high risk areas will be marked with high visibility paint or another approved method
■ All openings or potential openings properly secured
■ Fall protection plan will be established
■ Based on information collected additional requirements may be needed such as core testing, moisture analysis and other approved methods to determine the deterioration of the deck.
Prior to beginning any construction activities, the superintendent or foreman shall conduct a meeting with all employees to cover the hazards associated with the project. This meeting will cover the site-specific hazard assessment established during the Pre-Construction Inspection and the specific fall protection requirements of the work area. Employees will be informed of potential risk areas that have been previously identified and marked to establish controlled access zones prior to work commencing.
In areas where the deterioration of the roof deck has been detected and poses an immediate fall risk 3/4- inch plywood shall be installed to span the affected areas. The use of either a Safety Net System or Personal Fall Arrest System will be required in these areas until management has determined the area to be safe. Employees will also need to be informed of the potential fall hazards associated with the removal of existing materials. The top layers of roofing material may provide a certain amount of structural support that may be hiding a deteriorating deck. Therefore, removing the top layer of material will increase the risk of falls through the deck.
The superintendent or foreman will instruct all employees to stop all work immediately if any unidentified hazards are discovered during normal construction activities. The superintendent or foreman shall inspect the area and take the appropriate action to ensure the safety of the employees.
The above information is a general overview for establishing a deck inspection program and does not cover every situation that may arise for a contractor. Contractors should look at a deck inspection program as a living document that is sure to change throughout a roofing project. It will need to be updated each time a hazard is found to ensure employees’ safety and should be revaluated on an annual basis as part of a company’s comprehensive safety program. I strongly encourage contractors to involve their employees in this process and listen to their input in developing the right plan for each job performed by your company.
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