Rooftop Fall Protection for General Industry
Fall Protection Program Fundamentals – Part 3
Some of the most frequently misapplied, when not disregarded altogether, safety standards in the ATO workplace are those pertaining to rooftop fall protection. OSHA regulations for general industry are quite clear:
Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder.
Hence, only one type of rooftop fall protection is allowed for general industry workplaces: standard railing.
Well ……. almost.
Several decades ago OSHA started proposing changes to fall protection regulations in the Federal Register. OSHA will not cite an employer for a violation when they are compliant with a proposed change that’s published in the Federal Register. The OSHA rule making process is long and arduous. That is part of the reason that OSHA’s proposals for changing fall protection standards have not yet been adopted. As a result, OSHA has changed its proposal several times in response to advances in the fall protection field. OSHA’s latest proposal was published in the Federal Register on 05/24/2010: FR# 75:28862-29153.
The Section from the proposal containing the rules pertaining to roofs is 1910.28 Duty to have fall protection [see page 29139 of the OSHA proposal].
Sec. 1910.28(b) Protection from fall hazards.
(1) Unprotected sides and edges.
The employer shall ensure that each employee on a walking-working surface (horizontal and vertical) with an unprotected side or edge which is 4 feet or more above the lower level is protected from falling by the use of one or more of the following:
{tab (i) Guardrail}
The required guardrail system is described in Section 1910.29(b) of the OSHA proposal [see page 29142 of the OSHA proposal]. Figure D-10 from the proposal:
{tab (ii) Designated area}
The designated area system is described in Section 1910.29(d) of the OSHA proposal [see page 29143 of the OSHA proposal].
A good description of the designated work area system is provided in the ASSE publication Professional Safety, September 2007. The depiction below is from that article.
(i) Employees must remain within the designated area while work operations are underway;
(ii) The work must be of a temporary nature, such as maintenance on roof-top equipment;
(iii) Designated areas may be established only on surfaces that have a slope from the horizontal or 10 degrees or less (slope of the common walk-able 4-in-12 roof to flat).
(iv) The perimeter of the designated area must be delineated with a line consisting of a rope, wire, or chain. Specific, and substantial, criteria for the delineation system is provided on page 29143 of the OSHA proposal at 1910.29(d)(2) thru (d)((4).
Note:
- The required 6′ setback from the unprotected edge. The designated area system for fall protection will not work for work tasks that must be completed within 6′ of the fall edge. This required 6′ setback may also be one of the sources where the myth that simply ordering employees to remain 6′ from the edge is an acceptable “administrative control” for rooftop work.
- Access to the designated area is a clear path delineated by two lines of the rope, wire, or chain used to delineate the designated work area.
- Painted lines, red or other color, are not sufficient for delineating the designated work area, not path(s) to it.
{tab (iii) Safety net}
The safety net system is described in OSHA standards for Construction: 29 CFR 1926.502(c). Note: The OSHA proposal merely references the Construction standard from the General Industry standard. Construction standards themselves apply if the work being performed is
{tab (iv) Travel restraint}
The travel restraint system is described in Subpart I of OSHA’s General Industry regulation as documented at Section 1910.140 of the OSHA proposal [see page 29148 of the OSHA proposal].
A travel restraint system is a combination of an anchorage, anchorage connector, lanyard, and body harness intended to be used by the employee to limit travel to prevent exposure to a fall hazard.
A travel restraint system is used such that it does not support any portion of the employee’s weight; other wise the system would be a positioning system or a personal fall arrest system.
Specific and substantial requirements for travel restraint systems are provided at Section 1910.140(c) of the OSHA proposal [see page 29148 of the OSHA proposal].
{tab (v) Personal fall arrest}
Specific and substantial requirements for personal fall arrest systems are provided at Section 1910.140(c) and (d) of the OSHA proposal [see page 29148 of the OSHA proposal].
The following video provides a good depiction of a personal fall arrest system.
{modal url=”https://www.youtube.com/embed/hpXkaJGXJ5k” width=”400″ height=”225″}Video{/modal}
{/tabs}
OSHA will find that the failure to use a perimeter guardrail system around a roof to be a de minimis violation if one of the other four methods of fall protection is utilized.
Notice, there is no provision for the use of a “safety observer.” Likewise there is no provision for a painted warning line nor warning rope or cable.
While based on an earlier version of the OSHA proposed changes, a couple of articles from industry sources provide a good explanation of the process, description of a designated area, and comparison to fall protection rules for Construction found in 29 CFR 1926 Subpart M. The eLCOSH article also addresses some of the myths heard around the ATO; like “the 6′ rule.”
File an employee report of a suspected unsafe condition via the UCR report page from the FAA’s SMIS home page (https://smis.faa.gov) or ATO TSAP portal if you encounter a situation where a normally complaint fall protection system has been compromised.
A grievance is appropriate when encountering a normally unprotected rooftop edge on a roof where maintenance tasks are performed. A editable grievance template/form is provided in ATO Safety Reference Documents.
