22 Dec Residential Roofing – Fall Protection Requirements

Residential Roofing – Fall Protection Requirements

Residential roofing fall protection is required whenever employees are exposed to fall hazards of 6 feet or more above a lower level. Residential roofing work presents significant fall hazards from roof edges, steep slopes, openings, skylights, ladders, and unstable or slippery walking surfaces.

Important: The older OSHA interim residential fall-protection policy that permitted alternative procedures based on roof slope and a 25-foot fall height is no longer OSHA’s general policy. OSHA rescinded that directive effective June 16, 2011. Residential construction employers are generally required to comply with 29 CFR 1926.501(b)(13).

Fall Protection Requirements

Employees performing residential construction activities 6 feet or more above lower levels must generally be protected by one of the following conventional fall-protection systems:

• Guardrail systems.
• Safety net systems.
• Personal fall arrest systems (PFAS).

Alternative methods may be used only where permitted by OSHA. An employer that can demonstrate that conventional fall protection is infeasible or creates a greater hazard may use a written, site-specific fall protection plan meeting the requirements of 29 CFR 1926.502(k).

Cost, convenience, or a desire to complete the work faster does not establish infeasibility.

Personal Fall Arrest Systems

When a personal fall arrest system is used:

• Employees must wear an approved full-body harness.
• Body belts must not be used as part of a personal fall arrest system.
• Anchorage points must meet applicable OSHA requirements.
• Connectors, lanyards, lifelines, and deceleration devices must be compatible and appropriate for the system.
• The system must be rigged to prevent employees from striking a lower level.
• Equipment must be inspected before each use.
• Damaged or defective fall-protection equipment must be removed from service.
• Employees must be trained in the proper use of their fall-protection equipment.

Never tie off to plumbing vents, roof sheathing, guardrails, or other structures that have not been designed or approved as suitable anchorage points.

Roof Openings and Skylights

Roof openings can be just as dangerous as unprotected roof edges.

• Protect holes and openings with appropriate covers, guardrails, or other OSHA-compliant systems.
• Covers must be capable of supporting the required loads and be secured against accidental displacement.
• Covers should be clearly identified when required.
• Do not step, sit, or place materials on skylights.
• Treat skylights as openings unless they are demonstrated to meet applicable strength requirements or are otherwise properly guarded.

Inspect the Roof Before Work Begins

Before employees access the roof, inspect the work area for hazards such as:

• Damaged, deteriorated, or weak roof decking.
• Unprotected edges.
• Holes and skylights.
• Loose roofing materials.
• Wet, icy, oily, or otherwise slippery surfaces.
• Electrical hazards.
• Unsafe access points.
• Improper or inadequate anchorage locations.
• Materials or equipment that create trip hazards.

Correct identified hazards or establish appropriate controls before work proceeds.

Weather Conditions

Roofing work becomes considerably more hazardous during adverse weather.

Employees should not perform roofing work when conditions make footing, balance, or fall-protection systems unsafe. Consider:

• High winds.
• Rain.
• Snow or ice.
• Lightning.
• Extreme heat or cold.
• Wet or slippery roofing surfaces.

Supervisors should evaluate changing conditions throughout the workday and stop work when conditions become unsafe.

Materials and Housekeeping

Good housekeeping reduces both fall hazards and falling-object hazards.

• Keep access routes and walking surfaces clear.
• Do not allow scrap materials, cords, hoses, tools, or equipment to create trip hazards.
• Secure lightweight materials that could be displaced by wind.
• Keep materials away from roof edges unless properly secured and necessary for the work.
• Do not throw roofing materials or debris from the roof unless an approved controlled-disposal method is being used.
• Protect employees and others below from falling objects.

Never allow materials or equipment to interfere with fall-protection systems.

Ladder and Roof Access

Use a safe, designated means of accessing and leaving the roof.

• Inspect ladders before use.
• Set ladders on stable, level surfaces.
• Secure ladders when required.
• Maintain three points of contact while climbing.
• Do not carry materials that prevent safe climbing.
• Keep the roof access and landing area clear.
• Never climb structural members, scaffolding braces, or other makeshift access points.

Training

Employees exposed to roofing fall hazards must receive appropriate fall-protection training.

Training should address:

• Recognition of fall hazards.
• Procedures for minimizing those hazards.
• Correct use of guardrails, personal fall arrest systems, and other protective systems.
• Proper selection and use of anchorages.
• Inspection and care of fall-protection equipment.
• Roof openings and skylights.
• Safe ladder and roof-access practices.
• Falling-object hazards.
• Applicable limitations of fall-protection systems.
• Emergency and rescue procedures.

Employees must understand the fall-protection system being used before they begin roofing work.

Rescue Planning

A worker who falls while wearing a personal fall arrest system may remain suspended in the harness and require prompt rescue.

Before work begins:

• Determine how a suspended employee will be rescued.
• Ensure appropriate rescue equipment and personnel are available.
• Do not rely solely on calling emergency services when that would not provide sufficiently prompt rescue.
• Employees should understand how to summon assistance following a fall.

Remember

Residential roofing fall protection begins before anyone steps onto the roof. Inspect the work area, provide safe access, protect employees from roof edges and openings, use appropriate fall-protection systems, and stop work when conditions become unsafe.

Being tied off may take a few extra moments. A fall can change a life in seconds.