Rob Foote, President, Roofing Risk Advisors
From a risk management perspective, using personal fall arrest systems (PFAS) is one of the the most effective methods to control falls from elevations. There are other fall protection options permitted by OSHA, depending on the slope and size of the roofing system. We recommend the usage of PFAS, as one of the most effective fall protection methods to reduce the probability of a serious injury or death.
Roofers installing tiles risk permanent injury or death from falls. Even experienced roofers are exposed to unpredictable fall hazards caused by uneven sheathing, sudden gusts of wind, loose roofing materials and surfaces that become slick when wet. Taking appropriate fall protection measures can reduce risks and save lives.
Employers must provide a training program for each worker who might be exposed to fall hazards. The program must enable each worker to recognize the hazards of falling, and must train each worker in the procedures to follow to minimize these hazards. For fall protection training requirements, refer to 29 CFR 1926.503. In all cases, employers must evaluate the hazards and take measures to reduce the risk of falls.
Before beginning the job, focus on identifying fall protection needs. Survey the roof to determine whether there are pre-installed anchorages available that can be used. If not, begin planning immediately to identify the systems needed to protect workers from falls and have them available before the workers report to the job.
The contractor that is building and sheathing the roof structure will need fall protection equipment for workers performing these jobs. At a pre-construction meeting, or the first meeting on the worksite, ask the building contractor to leave roof anchors or other fall protection equipment in place after sheathing is completed.
Roofers must use fall protection equipment that meets OSHA requirements whenever they work 6 feet or more above a lower level. States with OSHA-approved state plans may have additional requirements beyond OSHA requirements. Depending on the tasks involved, where the work is taking place and other circumstances specific to tile roofing, contractors may be able to protect their workers using the following equipment: scaffolds, aerial lifts, PFAS and guardrails.
Safeguarding against hazards is as important to preventing fatal falls as having good fall protection equipment. When work begins on a roof, employers must prepare the site by protecting workers from the following hazards that could cause them to fall.
Wet or Windy Weather – Roofing should only be performed when weather permits. Wind and rain put workers at a greater risk for falling. In damp or windy weather, put work on hold until conditions improve. Skylights and Openings – Every year, workers die from
falling through openings and weak surfaces on roofs. Employers must use covers, PFAS or guardrails to protect employees working around skylights and roof openings.
Accessing the Roof – Employers must provide safe roof access and make sure that workers know how to get up and down from a roof in a way that minimizes the risk of falling. Extension ladders must extend at least 3 feet above the roof level to ensure safe access to the roof. For other requirements on the safe use of ladders, refer to 29 CFR 1926 Subpart X—Stairways and Ladders.
Staging Materials – Employers must put all working materials in safe spots. Loose tiles and hand-held equipment create tripping hazards. Workers can fall after tripping or slipping on something they did not see. While walking on the roof and carrying materials, the worker should keep the materials on the down-sloped edge to prevent the materials from falling into him- or herself if the materials are dropped.
Performing Edgework – When installing the first rows of tile near the roof edge, workers have several fall protection options. In addition to a PFAS, scaffolds and aerial lifts can provide safe access to the edge:
■ Scaffolds: When properly constructed and used, external scaffolds can provide suitable protection for roof repairs along the edge of the roof. Pump-jack scaffolds offer a secure platform from which to work and can be raised and lowered for specific tasks, such as working from underneath the eaves. Guardrails along the scaffold will provide fall protection. For other requirements for scaffolds, refer to 29 CFR 1926 Subpart L—Scaffolds.
■ Aerial Lifts: A portable boom lift can allow roofers easy access to the leading edge of the roof. The adjustable angle is useful for working on roofs of all grades. It offers an easy place for workers to tie off their lifelines and to work from within the basket. Care must be taken when loading material. Do not let workers overload the lift. For other requirements for lifts, refer to 29 CFR 1926.453—Aerial Lifts.
There are many methods available to protect workers from falls, but the method used should be determined by the unique characteristics of each job site.
A PFAS is a tool available to roofers during installation jobs, and is the system of choice for many roofers. However, a breakdown in any component of a PFAS could be disastrous for a worker.
The system includes three major components:
■ An anchorage to which the other components of the PFAS are rigged
■ A full body harness worn by the worker
■ A connector, such as a lanyard or lifeline, linking the harness to the anchorage. A rip-stitch lanyard, or deceleration device, is typically a part of the system.
Always follow the manufacturer’s instructions on selecting, installing and using PFAS components correctly. Some PFASs include special elevated anchor assemblies that permit the system to protect workers even when they stand near the anchor locations. Certain anchorage assemblies rotate or offer extension arms to improve mobility and prevent lifelines from contacting the roof surface. This is particularly useful during roof demolition when a line could catch on a nail or debris. For more information on the requirements for a PFAS, refer to 29 CFR 1926.502(d).
Remember that workers must use full-body harnesses in fall arrest systems. Body belts can cause serious injury during a fall, and OSHA prohibits their use as part of fall arrest systems.
When working in an area where a scaffold or aerial lift is not practical, workers can use a PFAS with a secure anchor. OSHA requires that anchors for a PFAS be able to hold at least 5,000 pounds of weight per person, or maintain a safety factor of at least two (twice the impact load) under the supervision of a qualified person [29 CFR 1926.502(d)(15)]. Anchors must not be attached to sheathing alone, since it may not be strong enough to hold the sudden weight of a falling worker. Anchors should be fixed to a strong structural
feature (like a sheathed truss). Always follow the manufacturer’s instructions or consult a qualified person when installing anchors. When choosing an anchor to use for fall protection, employers have a number of options, including the following:
■ Peak anchor: At the top of the roof, peak anchors are typically solid, nonmoving pieces secured by the anchor to the trusses underneath.
■ Permanent D-rings: Inexpensive D-ring anchors are attached to the truss frame; they are often removed after the job is done, although they can be left permanently on the roof.
When installing an anchor above the area being built, choose an anchor that is appropriate for the tile type and anchor location. Depending on the roof design, the best location might be at the peak of the roof, directly over a truss.
Otherwise, where practical, consider leaving anchors in place. It will make the current job simpler and reduce the burden for roofers in the future. Roofing is not always the last step in the construction process. Skylight windows and solar panels might be installed later during construction. Workers installing those units will also need fall protection anchors.
When working at heights of 6 feet or greater, if the employer does not use ladders, scaffolds, aerial lifts or fall restraint systems and can demonstrate that it is not feasible or would create a greater hazard to use conventional fall protection equipment (guardrails, safety nets or PFAS), the employer must develop a written site-specific fall protection plan in accordance with 29 CFR 1926.502(k). The plan must be prepared by a qualified person. This person could be the owner, the supervisor or any other worker who has extensive knowledge, training and experience with fall protection and is able to solve problems relating to fall protection.
The site-specific fall protection plan must document, for each location, why the use of conventional fall protection equipment is not feasible or will create a greater hazard. The plan must also describe the alternative methods that the employer will use so that workers are protected from falls. Workers and their supervisors must be trained on the proper use of those other fall protection methods.
Conventional fall protection equipment can reduce or eliminate the chances of a fatal fall. Otherwise, a written site-specific fall protection plan ensures that protection continues, even when conventional fall protection methods are determined to be unfeasible.
Rob Foote launched Roofing Risk Advisors, a division of Frank H. Furman, Inc. in 1992. Today, the agency is licensed in 50 states and is a trusted insurance and risk advisor for over 109 roofing professionals. RRA is a 15-year member of the National Roofing Contractors Association (NRCA) while Foote also serves on the boards of the Florida Roofing and Sheet Metal Contractors Association (FRSA) and several local roofing associations. Contact: Rob@furmaninsurance.com or 954-943-5050 ext. 214
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