Fall Protection in the Roofing Industry

Fall Protection in the Roofing Industry

Overview

Relationship of Subpart M (Construction) with other OSHA fall protection requirements

Fall protection requirements in Construction, Subpart M specifically for roofing activities

Multi-employer citation policy Q&A

MSUBPART

Fall Protection for Roofing

Two approaches on safety for falls:

– Fall Prevention – prevents employee from falling (e.g., guardrails, fall restraint systems, covers, skylight screens, warning lines, safety monitor)

– Fall Arrest – safely catches employee after they have fallen and before they strike a lower level. (e.g., personal fall arrest systems, positioning device systems, safety nets)

MSUBPART

Fall Protection for Roofing

1st Question-

Is the work being performed either inspection, investigation, or assessment prior to the start of construction work or after completion of the construction work?

If it is, Subpart M does not apply and fall protection is not required during these activities.

Fall ProtectionSUBPART

M

(Subpart M, 29 CFR 1926.500 – 503) Most work 6 feet above levels to which you could fall (primarily based on type of work activity or exposure condition):

– Ramps, runways, walkways, excavations, hoist areas, holes, formwork, reinforcing steel, leading edges, unprotected sides or edges, overhand bricklaying, roofing, pre-cast concrete erection, wall openings, residential construction, and other walking/working surfaces.

Fall Protection RequirementsM

SUBPART

Fall Protection for Roofing

Subpart M is like the general duty clause for fall protection in Construction (i.e., it covers fall protection when not specifically addressed by another standard).

For example, it does not cover:• employees on: scaffolds (Subpart L);• personnel platforms on a scaffold, crane or mobile

equipment; • stairways and ladders (Subpart X)• following activities: steel erection (Subpart R), towers &

tanks erection(1926.104), electrical power generation, transmission & distribution (Subpart V)

MSUBPART

Fall Protection for Roofing

Scope of Subpart M

Fall Protection for Roofing Work

Fall Protection for RoofingSUBPART

M

Roofing Work is defined in Subpart M as: hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including construction of the roof deck.

Subpart M covers fall protection for employees performing roofing work except when such employees are on equipment covered by another standard (e.g., scaffolds, personnel platforms, aerial lifts, stairways & ladders).

Employees involved in roofing work on steel erection sites are covered by Subpart R when such roofing work is performed during and as a part of the steel erection work (roofing material must serve as a structural component, such as could occur with some standing seam metal roof installs).

Holes (501(b)(4))- 2” or moreMORE PEOPLE FALL THROUGH ROOFS

THAN OFF OF THEM!!!!

Protection must be provided as soon as hole is created; protection prevents employees from tripping in or stepping into hole or falling into hole by either:

• Cover over• Guardrail around• Personal fall arrest system (PFAS) for employees• Restraint system to keep workers away from fall hazard

Cover all floor, ceiling, or working surface holes, including skylights, that are larger than 2 inches.- Must support twice the

weight of loads imposed at one time.

- Secure from horizontal displacement.

- Marked “hole” or “cover.”

- Must cover hole as soon as created

Hole Cover RequirementsAlso must provide falling object protection if

employees below

Fall Protection for RoofingMSUBPART

Skylights or larger deckholes can be covered,surrounded by barriers orhave nets put underneath.

Inadequate “cover”

Preventing Falls Through Roof Holes

Fall Protection for RoofingMSUBPART

Floor/Deck Hole Covers

Secured? Clearly Marked? Capable of supporting 2X weight imposed?

Fall Protection for RoofingSUBPART

M

Skylights– Requirements

• Must be protected with:– 3/4” Plywood Covers

» Twice the expected load

– Tables

– Fall Protection

– Skylight Nets

– Guardrails

Skylight Protection

– Tables– Covers– Nets– Flagged off

For roofing activities, Subpart M breaks down the allowed fall protective measures (other than for holes) into two categories:

residential 1926.501(b)(13)

non-residential 1926.501(b)(10 & 11)

Fall Protection for RoofingSUBPART

M

Guardrail Systems

Controlled Access Zones

Warning Line Systems

Safety Monitoring Systems

PersonalFall

Arrest Systems

Hole Covers

Canopies

Either provide conventional fall protection; i.e., PFAS, safety net, or guardrails; or follow the alternative protective procedures allowed (to be presented later).

For Non-residential roofing, alternative protective procedures are allowed only for low slope roofs (i.e., < 4:12). In other words, steep slope roofs require conventional fall protection ie. Guardrails, safety nets or personal fall arrest system. (501(b)(11)).

Basic Criteria for Both

MSUBPART

Fall Protection for Roofing

The run will always be twelve (12) inches

The following is an example of a slope measurement:

In this example, the slope is 2 and 12In this example, the slope is 2 and 12

The following fall protection systems can be used on a low sloped roof:

• If < 50 ft width or less, then safety monitor alone is allowed (no mechanical equipment 502(h)(2)).

• For >50 ft width, either:– Warning line and safety net

– Warning line and guardrail

– Warning line and PFAS, or

– Warning line and safety monitor

Any roof with a slope of 4 and 12 or less is considered low sloped. Greater than 4 and 12 is steep slope.

Low Sloped Roofs(4 and 12 or less)

Walkways must:– Have clear access– Protect against hazards– Designate area– Be reviewed with Crew

Method of CONVENTIONAL FALL PROTECTION Top rails must be between 39-45 inches high and withstand a lateral

force of 200 lbs.

A midrail must be placed between the top rail and the work platform and be able to withstand a force of 150 lbs.

When using wire rope as a guardrail the following criteria must be met:– There must not be more than a 2 inch deflection when a force of

200 lbs. is applied against it in any direction– Top rail must be flagged every 6 feet

Must have a toeboard to prevent debris from falling off roof (if there is no parapet wall)

Must be a minimum of four feet on each side of a material handling area

Subpart M (1926.502(b))

Guardrail Requirements

MSUBPART

Fall Protection for Roofing

Manufactured Guardrail Systems

This is one type of available guardrails foruse on flat roofs.

Too much Sag?

Toeboards prevent tools or materials from becoming falling objects.

Add screen or mesh if tools or materials extend above toeboards.

Store materials minimum 10’ from edge.

Toeboards

MSUBPART

Fall Protection for Roofing

Method of CONVENTIONAL FALL PROTECTIONComponents

If one of these parts fails, the system fails.

Personal Fall Arrest Systems (PFAS)

Fall Protection for RoofingSUBPART

M

– Capable of supporting at least 5,000 pounds per attached

employee or used as part of an PFAS that maintains a safety factor of at least ‘2’ (designed, installed and used under supervision of a qualified person).

– Independent of any anchorage being used to support or suspend platforms.

PFAS Anchorage Requirements

Fall ProtectionSUBPART

M

PFAS Devices

Roof bracket Rope grab on a lanyard withdeceleration device

Fall Protection for RoofingSUBPART

M

Sloped Roofing - PFAS

Anchorages

Fall Protection for RoofingSUBPART

M

PFAS DevicesFall Protection for Roofing

SUBPART

M

Limits fall to 2 feet or lessMust be attached directly to “D” ring on harness

– Shock absorber may prevent lock up, or lead to ratchet effect.

Line must be protected from damage over edges.Install and inspect in

accordance with manufacturer; some will work horizontally,while some will not.

Self-Retracting LifelineWatch swing hazards!

PFAS Devices

Horizontal Life Lines- must be designed, installed and used under the supervision of a qualified person-

maintain a minimum safety of factor of 2

Fall Protection for RoofingSUBPART

M

Please continue to Fall Protection Part II