You need to send an employee to your plant rooftop to check an air conditioning unit component. The employee will not be near the edge of the roof and the job should only take a few minutes. Should you provide fall protection for your employee?

This article will help you make those tough decisions from OSHA’s point of view.

Seeking guidance

Although OSHA’s general industry standards address fall protection in Subpart D — Walking-Working Surfaces, the regulations don’t adequately discuss safe procedures for walking and working on rooftops. But other documents, such as OSHA Letters of Interpretation, do provide guidance for employers.

OSHA requires fall protection at a height of four feet for industrial applications. For walkways, platforms, mezzanines, and other open-sided working surfaces, guardrails are the only method OSHA mentions for employee fall protection. Employers have questioned OSHA over what is considered a platform and, therefore, what would fall under the provisions of §1910.23(c) — Protection of Open-sided Floors, Platforms and Runways. In 1984, OSHA published Fall Protection in General Industry (STD 1-1.13), which clarifies this issue.

When employees work on an elevated surface on a predictable and regular basis (at least once every two weeks, or for a total of four man-hours or more during any sequential four-week period), the requirements at §1910.23(c) apply. Under those conditions, you need a guardrail around the platform’s perimeter. This requirement includes roofs. When employees are exposed to falls from elevated surfaces other than on a predictable and regular basis, personal protective equipment as required by §1910.132(a) or other effective fall protection must be provided.

Section 1910.132(a) simply states that you must provide and ensure that employees use PPE when they are exposed to hazards that can’t be eliminated by engineering or other effective methods. So, in reality, you are back to using either guardrails or another fall protection method. When guardrails are not feasible or impractical, OSHA allows other fall protection systems.

Parapets and guardrails

It could be a major expense to install guardrails around the perimeter of a building that employees access a couple of times a month. One option is to provide temporary or permanent guardrails around the work area. This requires training employees to stay inside the guardrails.

Some buildings have parapets that meet the height requirement and can be considered guardrails. An OSHA letter addresses “shorter” parapets, saying: A parapet height of 29 inches, where employees are exposed to falls from a roof, does not comply with the height requirement in 29 CFR §1910.23(e)(1) and cannot be considered acceptable by OSHA. The employer may install a temporary portable section of guardrail that will comply with 29 CFR §1910.23(e)(3)(v) and provide a minimum height of 36 inches at the exposure locations.

Tying-off

Depending on how much time your employees spend on a roof, you may want to install permanent tie-off (anchor) points. In an interpretation letter, OSHA states that when a standard guardrail is not feasible because it would result in impairment of the work being performed, alternate protection may be provided for employees. A tie-off system is acceptable as a method of meeting the intent of section 1910.23(c)(1).

When considering a tie-off system, you must also consider fall restraint versus fall protection. Fall restraint prevents a worker from getting close enough to an edge to fall. If the employee is protected by a restraint system, either a body belt or a harness may be used. Fall protection equipment arrests the fall and protects the employee in case of a fall. Fall restraint is probably the best system for roof work involving equipment maintenance, because you eliminate the chances of a fall. According to OSHA, it is acceptable to use fall restraint systems in place of guardrails, lifelines, or fall arrest equipment to protect employees from fall hazards. Employees can be within inches of the edge, as long as the restraint system prohibits the employee from falling off the edge.

OSHA suggests that, as a minimum, fall restraint systems should have the capacity to withstand at least twice the maximum expected force needed to restrain the person from exposure to the fall hazard.

Designated areas

Designated areas are explained in a Letter of Interpretation titled: “Alternative fall protection program when guardrails are infeasible to install.” Here, OSHA falls back on the proposed rule for walking and working surfaces that was first published in 1990. The proposed rule addressed work of a temporary nature, such as maintenance on rooftop equipment. It allowed employers to establish a designated area as an alternative to installing guardrails where they can demonstrate that employees within the designated area are not exposed to fall hazards. Other requirements for a designated area include:

• The work is temporary.
• The slope of the surface is ten degrees or less.
• The area is surrounded by a rope, wire or chain supported by stanchions meeting specific criteria.

The proposed rule — Walking-working surfaces and personal fall protection systems — is due to be published as a “new” Notice of Proposed Rulemaking (NPRM) in November 2006. In its 2006 Letter of Interpretation, OSHA says you can use the 1990 version now if your action clearly provides equal or greater employee protection or is determined to be safe by a letter.

Employers must take fall protection seriously, even when the distance from the work to the edge of a roof seems substantial enough or the time to do the work is brief. Where the potential for falls exists, protection must be provided.

Links

• Gerald Woodson