Fall protection for working on roofs

Responding is Daniel Huntington, North American training manager, Kee Safety Inc., Buffalo, NY.

Let’s start with the obvious. If you can wrap your entire roof in guardrail – do that. However, most of us have budget constraints and limited time. Combine that with the sheer enormity of potential fall hazards and a complex tangle of OSHA codes, and it’s easy to feel overwhelmed. This article will break down a simple, strategic approach to getting the most safety mileage out of limited resources and help you rethink the way you approach fall protection.

Statistically speaking, accidents are directly correlated with frequency of an activity. This simply means that the more you do something, the more likely you are to have an accident. Here’s an example. “Bob and Jim both live in Ohio. Both are Cincinnati Bengals fans. Jim has a wife and 2 children. Bob has a girlfriend but isn’t ready to commit. Who’s more likely to get into a motor vehicle accident?”

You don’t know.

What if I tell you Bob works for a trucking company and Jim works from home as a software developer? Frequency dictates that Bob has a much higher probability of an accident due to his occupation. In the same way, find the high-frequency areas of your rooftop and address those first.

Where are my high-frequency areas?

The answer is simple – access points. Let’s say your roof is accessed by an external fixed ladder and has an HVAC unit that is serviced once per quarter, an exhaust fan that gets a new belt once a year, and roof drains that are cleaned twice a year. Now, let’s break down each location by the frequency they are visited:

• HVAC unit – four visits/year
• Exhaust fan – one visit/year
• Roof drain – two visits/year

Most people would look at that list and say, “Easy, protect my HVAC unit first.” However, the hazard with the highest frequency is actually the ladder – with 14 visits a year! Once when you go up the ladder, and again when you come back down. Additionally, no other unit brings your employee in closer proximity to danger than the ladder.

OSHA addresses this proximity to danger. Many people feel intimidated trying to understand government regulation. This portion of code is the clearest direction from OSHA. According to the new fall protection standard for general industry, published in November 2016:

1910.28(b)(3)(iv) – Each employee is protected from falling into a ladderway floor hole or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset must be used.

Ladderways must be protected. However, what if your roof is accessed via a roof hatch? OSHA states in 1910.28(b)(3)(v)(A) that “When the hole is not in use, the employer must ensure the cover is closed or a removable guardrail system is provided on the exposed sides.” In my experience, 1 percent of people actually close the hatch, while the remaining 99 percent leave the lid open – leaving an open hole on the roof. Railing and a gate surrounding the hatch mitigate this risk without relying on the employee to manually open and close the roof hatch after every use.

I encourage you to address your rooftop access points immediately. If you require additional assistance or you want to take the next step, please call a professional and have an assessment conducted. An organized plan will pay for itself in no time.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.