Back to Basics is an article series that highlights important, but possibly overlooked, information facilities management professionals should know.
One of the first steps in establishing a successful fall protection program is identifying all fall hazards that exist inside, outside, and on top of your facility. Each facility is different and will have their unique hazards, but this article will discuss some of the most common rooftop fall hazards and simple solutions that will protect workers.
Fall protection requirements can vary based on industry or locality. However, this article will primarily reference federal OSHA 1910 General Industry standards where fall protection is required when employees are exposed to falls of 4 feet or more.
Rooftop Fall Protection Requirements
OSHA permits different types of rooftop fall protection equipment depending on the frequency of the work task being performed and the proximity of the worker to any unprotected roof edge. The standards are ambiguous when defining frequency of work, but OSHA interpretation letters help determine that work tasks that take two or fewer hours to complete and are sporadic, or not part of a typical routine, are referred to as “infrequent or temporary.” All other tasks that would not fall under these criteria are referred to as “regular and routine.”
When workers are less than 15 feet from the roof’s edge, OSHA requires the use of passive or active fall protection systems for all regular and routine workers. Warning line is permitted for regular and routine workers only when they are 15 feet or farther away from the roof’s edge. However, warning line is permitted for infrequent and temporary tasks occurring within 6 feet of the roof’s edge. Infrequent and temporary tasks require no fall protection if they are performed more than 15 feet away from the roof’s edge and within the presence of a safety monitor.
Common Hazard No. 1: Rooftop Perimeter
The rooftop perimeter can be a building’s greatest asset or fall hazard, depending on its design features. Rooftops must have parapets or guardrails at least 42” high as well as meet other strength requirements to be compliant with OSHA guardrail standards. If OSHA-compliant guardrail exists around the perimeter of the rooftop, then comprehensive rooftop safety can be easily achieved.
When buildings have no guardrail or parapet shorter than 42 inches, it should be determined what equipment within 15 feet of the roof’s edge must be serviced and how maintenance workers can be protected from falls. Parapets can be modified to meet the 42-inch requirement or free-standing guardrail panels can be installed. It is important to note that OSHA does not require guardrail to be permanently fastened to the rooftop to maintain compliance. Counterweighted guardrail panels (see Figure A) can bring rooftops into compliance without immediately requiring expensive roofing work to be performed.
Additionally, passive fall protection systems like guardrail are more effective in protecting workers as they prevent falls from occurring. Active fall protection systems using fall arrest equipment are effective at saving lives but will only lessen the severity of fall-related injuries. When perimeter guardrail is not a feasible option, horizontal lifeline systems (see Figure B) can provide tie-off for multiple workers and do not prohibit rooftop mobility.
Common Hazard No. 2: Permanent, Fixed Ladders
As of November 2018, OSHA 1910.28 requires all new permanent, fixed ladders to be equipped with a personal fall protection system, or ladder safety system, if there is a risk of falling 24 feet or greater to a lower level. Historically, ladder cages were accepted as sufficient fall protection, but that is no longer the case. This update does not mandate the removal of existing ladder cages unless the cage interferes with the installation or operation of the newly required fall protection equipment.
In the state of California, Cal/OSHA has this same requirement, but for ladders 20 feet or greater.
Eligible ladders built before 2018 have until November 2036 to be brought into compliance. However, retrofitting must occur simultaneously with any repairs, maintenance, or construction scheduled on the ladder performed before the 2036 deadline.
While OSHA’s mandate for fixed ladder fall protection begins at 24 feet, this author encourages to installation of these systems onto every fixed ladder. A worker falling off a 23-foot ladder would have the same experience, but their employer would not be legally required to install a ladder safety system. We should want to protect our employees because it is the right thing to do, not because of legal mandates. An employer simply interested in meeting OSHA minimums might accept the risk of the workers falling off the 23-foot ladder. However, an employer that prioritizes worker safety would likely install a system on the 23-foot ladder because the fall hazard is still present to the worker. OSHA compliance is an important milestone, but comprehensive worker safety should be the ultimate goal.
Common Hazard No. 3: Roof Hatches
Roof hatches are a common form of access on rooftops and pose significant fall hazards when in use. Hatch doors can be retrofitted with guardrail systems (see Figure C) that contain an automatically closing swing gate to allow for easy access on and off the ladder but prevent nearby workers from falling into the hatch when the door is open. Hatchway ladders 24 feet or greater would also be eligible for the previously mentioned OSHA 1910.28 update.
OSHA requires workers to always maintain three points of contact when climbing hatchway ladders. Difficult hatch door mechanisms can sometimes require one or both hands to leave the ladder, which is why accidents often happen during this transition period. Automatic roof hatch openers (see Figure D) open/close hatch doors and provide a safer climbing experience. They can also help illuminate the ladder during ascent by opening the hatch door from the ground and help avoid temporary bright-light blindness while climbing down by allowing the worker to safely close the hatch door from solid ground.
Common Hazard No. 4: Skylights
While skylights are not inherently exposed holes, OSHA treats them essentially as such. Most skylights are not rated for a human to fall on top of them without breaking through, and approximately a dozen maintenance workers die each year from accidental falls through skylights. The most effective remedy is another form of passive fall protection—skylight screens see Figure E). Screens can be easily installed and will prevent workers from falling through skylights.
Conclusion
Identifying fall hazards can be simple, but implementing effective fall protection solutions can be challenging. Despite the challenges, the work is too important to not overcome any difficulties. Approximately 450,000 workplace falls occur annually, with about 850 resulting in fatalities. The good news is that with proper training and equipment, all falls are preventable. If falls can be prevented, then lives can be saved.
Philip Jacklin is the Continuing Education Program Manager for Diversified Fall Protection. He is an AIA continuing ed provider, QSSP certified, OSHA-30 trained, and has been a partner to the fall protection industry since 2018.