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Rooftop Maintenance Tasks and Fall Protection: How Close can you get to the Leading Edge?

Workers With Nail Gun on Roof

Employers have more freedom to customize their fall protection plan under the new OSHA 1910 Walking-Working Surfaces Standard that went into effect in January. But they need to take great care: the flexibility it affords carries risk.   

The new rule redefines safe distances from the roof edge and the degree of protection required within specified footage. OSHA has also recognized other forms of fall protection such as fall restraint and arrest systems and included them as suitable solutions in the new standards. There’s also the nature of the job to consider: “temporary and infrequent tasks” conducted further from the edge require less stringent protection. Though these are only two stipulations in the update, they give employers and building owners the ability to choose between various fall protection equipment. This puts the onus on a decision maker who might not be aware of the pros and cons of safety equipment in certain scenarios.  

OSHA 1910 Walking-Working Surfaces Standard Requirements

OSHA estimates the rule will prevent 29 fatalities and 5,842 injuries annually. For general industry working at a 4-foot height, or a low sloped roof, OSHA requires:  

  • 6 feet from the edge: conventional fall protection (guardrail, fall restraint or fall arrest system) is required.
  • Between 6 feet and 15 feet from the edge: conventional fall protection (guardrail, fall restraint or fall arrest system) is required. A secured designated area in lieu of conventional fall protection is acceptable as long as the work is both “infrequent and temporary”
  • 15’ and greater from the edge: conventional fall protection (guardrail, fall restraint or fall arrest system) is required. The employer is not required to provide any fall protection, provided the work is both infrequent and temporary

Problem: “infrequent and temporary” work isn’t clearly defined. Employers can categorize a job as infrequent and temporary as they see fit. It could be a time saver to do so, but consider the implications if an injury occurs. Without a clear definition, employers could be exposing workers and themselves to danger, legal issues, and risk. In the event of a fall, can it be proved in the court of law that the worker was performing a task that was temporary and infrequent?

How frequently do workers access your roof?

Most commercial and manufacturing buildings have a variety of complex systems that are managed, repaired and otherwise maintained from the roof, including communications, plumbing, HVAC piping and other system controls. Depending on the scenario, the roof could be accessed three or four times per day and in some situations, access is required at night. Even if maintenance is required less often, accidents can happen in unexpected ways and in seemingly harmless scenarios. For example, 25 percent of fatalities reported in a recent NIOSH study occurred from a 6 to 10-foot fall from a ladder.  

Permanent solutions like guardrails are actually a time-saver and a solid safety net regardless of the situation because they are already established and OSHA compliant. We recommend that employers and building owners take extra precautions and conservative safety measures–it’s our goal to keep our clients and their working environment safe. Should you go outside of the OSHA 1910 Walking-Working Surfaces Standard law and do more? We think yes. Gravity doesn’t take a break and neither should we in our efforts to protect the American workforce.

Questions about appropriate rooftop safety practices? Contact us.

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