Roofing Contractor Safety Manual

What Should a Roofing Contractor Safety Manual Include?

The contents of a Roofing Contractor Safety Manual should reflect the company’s actual operations.

A residential roofing contractor performing steep-slope tear-offs and installations may have different hazards than a commercial contractor installing membrane roofing on large low-slope roofs. Contractors performing roof repairs, sheet-metal work, waterproofing, coatings, torch-applied roofing, or work at industrial facilities may require additional safety procedures.

The manual should begin with Core Construction Safety Programs and then add programs based on the company’s roofing systems, equipment, materials, work environments, and employee exposures.

Core Safety Programs for Roofing Contractors

A comprehensive Roofing Contractor Safety Manual may include core programs addressing:

• Accident and Incident Investigation.
• Emergency Action Plan.
• Fire Prevention.
• First Aid.
• Hand and Power Tool Safety.
• Hazard Communication.
• Hand and Power Tool Safety.
• Job Safety Analysis (JSA/JHA).
• Manual Lifting and Material Handling.
• Personal Protective Equipment.
• Slips, Trips and Falls.
• Walking-Working Surfaces.
• Electrical Safety.
• Ladder and Stairway Safety.

The manual should also establish responsibilities for management, supervisors, employees, competent persons, hazard identification, workplace inspections, safety training, hazard correction, incident reporting, recordkeeping, and periodic review of the company’s safety programs.

Fall Protection for Roofing Contractors

Fall protection is one of the most important components of a roofing contractor’s safety program.

Roofing employees may be exposed to unprotected roof edges, holes, skylights, leading edges, changes in elevation, ladders, scaffolds, aerial lifts, and other elevated work areas.

Fall-protection procedures should address the types of roofing work the company performs and the fall hazards employees may encounter.

Depending on the work and applicable OSHA requirements, fall-protection systems may include:

• Guardrail systems.
• Personal fall arrest systems.
• Safety net systems.
• Fall-restraint systems where appropriate.
• Warning-line systems where permitted.
• Safety-monitoring systems where permitted.
• Covers for holes and openings.
• Other fall-protection measures permitted for the particular operation.

Employees should be trained in the fall-protection systems and procedures applicable to their work.

Fall-protection equipment should be inspected, maintained, stored, and removed from service when defective.

Low-Slope Roofing

Low-slope roofing presents different work conditions and fall-protection options than steep-slope roofing.

Roofers may work on large commercial or industrial roofs while installing insulation, membrane systems, coatings, flashing, sheet metal, or other roofing materials.

Planning should consider:

• Unprotected roof edges.
• Roof openings and skylights.
• Access points.
• Material-staging locations.
• Warning-line placement where permitted.
• Personal fall-protection requirements.
• Mechanical equipment.
• Falling-object hazards.
• Roof condition and structural integrity.
• Other contractors working on or below the roof.

The fall-protection method selected should comply with the requirements applicable to the roofing work being performed.

Steep-Slope Roofing

Steep-slope roofing creates significant fall hazards because employees work on inclined surfaces where footing and balance may be more difficult to maintain.

Roofing contractors should plan for safe access, fall protection, material placement, tool use, weather conditions, and movement on the roof.

Employees should understand the fall-protection system being used and how to properly inspect, connect, adjust, and use applicable equipment.

Materials and equipment should be positioned so they do not create additional fall, trip, or falling-object hazards.

Residential Roofing Safety

Residential roofing commonly involves steep roofs, ladders, tear-off operations, material delivery, power tools, changing weather, and employees working near unprotected roof edges.

Safety planning should consider the work from initial access through completion of the project.

Important considerations may include:

• Roof access.
• Fall protection.
• Ladder setup and use.
• Roof openings.
• Material delivery and staging.
• Tear-off operations.
• Falling materials.
• Power tools.
• Electrical service and overhead power lines.
• Heat and weather exposure.
• Housekeeping
• Protection of occupants and the public.

Residential roofing contractors should ensure that fall-protection procedures reflect the requirements applicable to residential construction and the roofing activities being performed.

Commercial and Low-Slope Roofing Safety

Commercial roofing frequently involves larger roof areas, mechanical equipment, membrane systems, insulation, adhesives, coatings, hot work, roof openings, skylights, and interaction with building occupants or other contractors.

The contractor should evaluate both the roofing work and the conditions of the facility.

Additional considerations may include:

• Roof access and restricted areas.
• Warning lines and fall-protection systems.
• Mechanical equipment.
• Skylights and roof openings.
• HVAC and electrical equipment.
• Chemical products.
• Hot asphalt or torch-applied systems.
• Material handling and storage.
• Crane or hoisting operations.
• Work around building occupants.
• Emergency access and evacuation.

Ladders and Roof Access

Ladders are one of the most frequently used means of accessing roofing work.

The company’s Ladder Safety Program should establish requirements for ladder selection, inspection, setup, positioning, climbing, use, and removal of defective ladders from service.

Roof-access planning should consider:

• Stable ladder placement.
• Proper extension above the landing surface when required.
• Securing ladders where necessary.
• Maintaining safe climbing practices.
• Keeping access areas clear.
• Electrical hazards.
• Employee movement between the ladder and roof.
• Material handling.

Employees should not use damaged or inappropriate ladders.

Scaffolds, Aerial Lifts and Other Access Equipment

Roofing contractors may use scaffolds, aerial lifts, boom lifts, scissor lifts, or other equipment to access work areas or perform roofing-related tasks.

Applicable safety procedures should address equipment inspection, setup, authorization, fall protection, work-area conditions, electrical hazards, load limitations, overhead hazards, and safe operation.

Employees should receive the training required for the equipment they operate or use.

Roof Openings and Skylights

Roof openings and skylights can create serious fall hazards.

Roofing contractors should identify openings before work begins and as work progresses.

Appropriate protection may include covers, guardrails, personal fall-protection systems, or other measures required for the conditions.

Employees should not assume that a skylight can support their weight or provides fall protection simply because it is covered by glazing or another material.

Falling Objects and Protection Below Roofing Work

Roofing work can expose employees and others below to falling tools, materials, debris, and equipment.

Contractors should evaluate the areas beneath roofing operations and establish appropriate controls.

Depending on the work, controls may include:

• Barricades.
• Restricted-access areas.
• Toeboards.
• Material-control procedures.
• Tool-control practices.
• Debris chutes.
• Hard hats.
• Controlled material lowering.
• Scheduling work to reduce exposure below.

Employees should avoid throwing roofing materials or debris from elevated locations unless an appropriate controlled method has been established.

Hand and Power Tools

Roofing contractors use numerous hand and power tools, including nail guns, saws, drills, grinders, cutters, tear-off tools, and other portable equipment.

Tools should be appropriate for the task, maintained in safe condition, inspected as necessary, and used according to manufacturer instructions.

Safety procedures should address applicable hazards such as:

• Cutting and puncture injuries.
• Flying particles.
• Electrical hazards.
• Tool guarding.
• Pneumatic pressure.
• Noise
• Dust
• Repetitive motion.
• Improper tool use.

Required PPE should be selected based on the tool and work being performed.

Material Handling and Manual Lifting

Roofing materials can be heavy, bulky, awkward, or difficult to handle safely on ladders and elevated surfaces.

Planning should address delivery, unloading, hoisting, staging, carrying, and installation of materials.

Mechanical equipment should be used when practical to reduce manual handling. Employees should avoid carrying materials in a manner that interferes with safe ladder climbing or fall protection.

Materials placed on roofs should be positioned to avoid overloading structural surfaces and creating trip, fall, or falling-object hazards.

Heat Stress and Sun Exposure

Roofing work can expose employees to significant heat because of direct sunlight, high outdoor temperatures, physically demanding work, and heat reflected or absorbed by roofing materials.

Employers should evaluate heat conditions and implement appropriate controls.

Depending on conditions, heat-illness prevention measures may include:

• Drinking water.
• Rest breaks.
• Shade or cooling areas.
• Acclimatization
• Adjusting work schedules.
• Monitoring employees.
• Training employees to recognize heat-related symptoms.
• Emergency-response procedures.

Employees should be encouraged to report symptoms of heat illness promptly.

Cold, Wind and Severe Weather

Roofing contractors should also evaluate cold temperatures, high winds, rain, ice, lightning, and other weather conditions that can make roofing work hazardous.

Weather can affect footing, ladder stability, material handling, equipment operation, fall-protection systems, and employee physical condition.

Work should be stopped or modified when weather conditions make the planned operation unsafe.

Electrical Hazards and Overhead Power Lines

Roofing employees may work near electrical service entrances, overhead power lines, rooftop electrical equipment, temporary power, extension cords, and portable electrical tools.

Electrical hazards should be identified during work planning.

Particular attention should be given to conductive ladders, long materials, cranes, lifts, equipment, and other objects capable of contacting overhead electrical lines.

Employees who are not qualified to perform electrical work should not perform tasks requiring electrical qualification.

Hazard Communication, Adhesives and Roofing Chemicals

Roofing materials may include adhesives, primers, coatings, solvents, sealants, cleaners, fuels, and other chemical products.

The company’s Hazard Communication Program should address applicable requirements for:

• Chemical inventories.
• Safety Data Sheets.
• Labels.
• Employee information and training.
• Storage
• Handling.
• Required PPE.
• Spill response.
• Flammable materials.
• Communication of hazards to other employers where applicable.

Employees should understand the hazards associated with the products they use.

Silica, Dust and Respiratory Hazards

Some roofing operations can generate dust or disturb materials that create respiratory hazards.

Potential exposures may occur during cutting, drilling, grinding, demolition, tear-off, or disturbance of concrete, masonry, tile, or other silica-containing materials.

Older buildings may also contain materials requiring evaluation for asbestos or lead before disturbance.

Where respiratory hazards are present, employers should evaluate employee exposures and implement applicable engineering controls, work practices, respiratory protection, and training.

Hot Work, Torches and Fire Prevention

Some roofing systems involve open flames, torches, hot asphalt, heat-producing equipment, or other ignition sources.

Where these operations are performed, safety procedures should address applicable fire and burn hazards.

Controls may include:

• Removal or protection of combustible materials.
• Appropriate fire extinguishers.
• Inspection of hoses, regulators, and equipment.
• Compressed-gas-cylinder safety.
• Hot-work authorization where applicable.
• Fire watches when required.
• Monitoring for concealed ignition.
• Safe storage and handling of fuels and flammable materials.

Employees performing hot work should be trained in the procedures applicable to the operation.

Job Safety Analysis for Roofing Work

A Job Safety Analysis (JSA/JHA) can help roofing contractors evaluate the hazards associated with individual work activities before work begins.

Roofing JSAs may address tasks such as:

• Roof access.
• Tear-off operations.
• Material delivery.
• Material hoisting.
• Steep-slope roofing.
• Low-slope roofing.
• Ladder use.
• Scaffold use.
• Aerial-lift operation.
• Power-tool use.
• Hot work.
• Work near roof openings.
• Work near electrical hazards.

The JSA should reflect actual job conditions and should be reviewed when work methods, equipment, weather, personnel, or other conditions change significantly.

Additional Safety Programs for Roofing Contractors

In addition to Core Safety Programs and Fall Protection, roofing contractors should select additional programs based on their actual operations.

Depending on applicability, these may include:

• Aerial and Boom Lift Safety.
• Asbestos Awareness.
• Bloodborne Pathogens.
• Cold Stress.
• Compressed Gas Cylinders.
• Driving and Fleet Safety.
• Drug and Alcohol Programs.
• Fall Protection.
• Flammable and Combustible Liquids.
• Hearing Conservation.
• Heat Stress Prevention.
• Lockout/Tagout.
• Respiratory Protection.
• Scaffolding.
• Scissor Lift Safety.
• Silica Exposure.
• Spill Prevention and Response.
• Traffic Control.
• Welding, Cutting and Hot Work.
• Working Around the Public.
• Working in Occupied Areas.
• Working Alone.
• Workplace Security.
• Other programs applicable to the company’s operations.

The objective is not to fill the manual with every available safety program. Programs should be selected because they reasonably apply to the company’s roofing activities, equipment, hazards, or workplace environments.

Roofing Contractors Working at Occupied Buildings

Roof repair and replacement frequently occur while homes, businesses, schools, offices, industrial facilities, and other buildings remain occupied.

Contractors should consider hazards that their work could create for occupants, customers, employees, pedestrians, and other contractors.

Controls may include:

• Restricted-access areas.
• Barricades and signs.
• Protection from falling materials.
• Controlled material delivery.
• Safe access around the building.
• Coordination with the building owner.
• Emergency access.
• Noise and dust controls.
• Chemical and odor considerations.
• Housekeeping and debris removal.

Site conditions should be evaluated throughout the project as roofing work moves to different areas.

Roofing Toolbox Talks and Safety Communication

Roofing conditions can change rapidly because of weather, project progress, materials, equipment, and the activities of other contractors.

Toolbox talks can be used to reinforce safety requirements and discuss hazards relevant to current work.

Useful roofing toolbox-talk topics may include fall protection, ladder safety, heat stress, power tools, PPE, roof openings, housekeeping, material handling, electrical hazards, weather, and fire prevention.

Toolbox talks supplement required training but do not replace training specifically required by applicable OSHA standards.

Roofing Safety Manual vs. Site-Specific Safety Plan

A Roofing Contractor Safety Manual establishes the company’s overall safety policies, programs, and procedures.

A Site-Specific Safety Plan (SSSP) applies relevant requirements to a particular roofing project.

For example, the company’s safety manual may contain its Fall Protection, Ladder Safety, Hazard Communication, Emergency Action, and Heat Stress procedures. A Site-Specific Safety Plan can then address the particular roof, access locations, fall hazards, emergency arrangements, electrical hazards, occupants, material-staging locations, and other conditions associated with that project.

The company safety manual therefore provides the foundation for project-specific planning when an SSSP is required or appropriate.

Building a Roofing Contractor Safety Manual

A practical Roofing Contractor Safety Manual should reflect the types of roofs, materials, equipment, and work the company’s employees actually encounter.

When determining which programs to include, consider:

• Residential or commercial roofing.
• Steep-slope or low-slope work.
• New construction, repair, replacement, or tear-off.
• Fall hazards and access methods.
• Ladders, scaffolds, lifts, and hoisting equipment.
• Tools and machinery.
• Roofing materials and chemicals.
• Hot work or torch-applied roofing.
• Heat, cold, and weather exposure.
• Electrical hazards.
• Dust and respiratory exposures.
• Work around building occupants or the public.
• Applicable OSHA requirements.
• Customer and contractor-prequalification requirements.

Selecting programs according to actual operations produces a safety manual that is more useful to employees and easier for the company to administer.

Customized Safety Manuals for Roofing Contractors

Roofing contractors can request a customized Construction Safety Manual containing the Core Safety Programs and additional programs applicable to their roofing operations, equipment, hazards, and workplace environments.

Programs can be selected according to the company’s actual work, allowing the manual to address residential, commercial, steep-slope, low-slope, repair, replacement, or other roofing activities without being filled with unrelated programs.

Individual safety programs can also be selected when a roofing contractor needs to add or update a particular program within an existing manual.