Bill Coombs, Safety and Loss Control Consultant, FRSA SIF
The OSHA requirement for fall protection is the same for residential or commercial workplaces and states that “any worker working six feet or more above a lower level, must be protected by some form of fall protection.” This rule applies to all trades working in the construction industry. The roofing industry actually has more flexibility than many other trades when it comes to fall protection. OSHA allows for the use of a safety monitor as fall protection when roofing work is being done on a low slope roof (4:12 or less) that is less than fifty feet in width (width is always the smallest dimension). The problem we have seen is often there will be several workers on the roof, all working in different areas and working with no true safety monitor on the job. If OSHA pulls up to a jobsite
and sees that all workers are busy working and not tied off, the contractor is in violation of the fall protection standard which will more than likely result in a citation and fine. A safety monitor is the absolute bare minimum a contractor must have on the site. A safety monitor cannot have any other responsibilities or duties, must be on the same level as workers, and be close enough to communicate verbally to warn of a potential safety hazard. If the roof is over fifty feet in width, warning lines must be set up six feet from the roof edge and if a worker goes outside the warning line they must have a safety monitor watching them at all times, or they must be attached to a personal fall arrest system.
The fall protection systems that meet the OSHA requirements are: a safety monitor, safety monitor and warning lines, warning lines and personal fall arrest, personal fall arrest, guardrails, safety nets, and scaffolds. If a contractor is not using the proper system for their job site, they likely will be cited under the OSHA regulations. On steep slope roofs, (over a 4:12 pitch) the only acceptable fall protection systems that can be used are personal fall arrest systems, guardrails, or safety nets. One of these systems must be set up, no exceptions. With these basic requirements for fall protection, how is it that workers still fall off roofs? From what we see as Loss Control Consultants in the field, it is often a lack of proper enforcement. When a contractor provides the equipment, and properly trains the workers on fall protection, they still have to make sure their employees adhere to the requirements. The foreman or supervisor on the job is the first line of management and must make sure all workers are doing what is required. If not, workers may be injured and companies may be fined by OSHA.
We hear all the excuses, “the equipment is uncomfortable,” “it slows us down,” “other companies are not using it,” and “we trip over the ropes.” Fall protection is required under the law and regardless of the complaints, contractors and their employees need to follow the law to keep workers safe. Equipment in good condition and adjusted properly will aid in the comfort of the wearer. Production may slow down a little at first, but as time progresses and the workers become more familiar with properly wearing it, the speed will return with little or no added time to complete the project. As far as tripping over the ropes, it really is no different than power cords and air hoses on the roof, which workers get used to avoiding. If the equipment is used properly the trip hazard is minimal. Plus, it is better to possibly stumble on the roof than it is to fall off it!
We have seen many times where workers will use the equipment when the boss is around, but as soon as they leave the jobsite, the fall protection comes off and the workers work without it. We have done job site inspections and told the workers what they need to do, we leave the jobsite and stop back thirty minutes later and no one has the fall protection on. This behavior should not be tolerated by the contractor, as a worker could be seriously injured or die from a fall. The employer must make sure all employees are doing what is required at all times and take necessary steps to make sure they comply.
Make sure your workers are trained and understand the fall protection standards, have the proper equipment, and know that you will enforce the standards as a requirement of their employment because there is no more important safety standard than fall protection in the roofing industry.
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