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Rooftops are dangerous places for workers, no matter how tall the building is. As an employer, it's vital that you understand that there is always a risk of someone slipping and falling while they're working on the roof. You're obligated to make sure that the fall risk is mitigated and that you follow the OSHA regulations for fall protection devices. However, deciding which roof fall protection system to use on your facility's roof isn't always an easy feat. Can you get by with guard railings, horizontal lifelines, or other roof lifeline systems or do you need to provide employees with additional personal protection equipment (PPE)? Is one a better choice than the other? Let’s take a closer look at each.
The purpose of guard railings is to prevent falls and to limit access to certain areas of the building. Anytime your people are expected to work 4 feet or more (for general industry, 6 feet or more for construction) above the lower level on elevated work surfaces, landings, platforms, or an accessible low-slope or flat rooftop, you need to have guardrails in place. It is also necessary to install guardrails around roof openings that a worker could accidentally walk over and fall into.
To be compliant with OSHA regulations, guard railings must:
In some cases, the size and slope of the rooftop is not conducive to the use of guard railings, or there is work that must occur outside of their perimeter. If this is the case for your facility, it warrants a different approach to fall protection: a lifeline system. Both horizontal lifelines and roof lifeline systems incorporate the use of a wire cable with stanchions that act to both arrest and restrain falls. These types of fall protection devices must be used in combination with a harness and lanyard.
To comply with OSHA regulations, both the lifeline and the PPE devices that are used must be designed, installed, and used under the supervision of a qualified person. Additionally, lifelines and PPE must:
Although OSHA requires employers to provide fall protection for their employees, it does not specify exactly which kind to use. The truth is, not every situation is suitable for guard railings and the only option is to use an alternative roof fall protection system, such as horizontal lifelines or other roof lifeline systems. This is generally a decision you have to make on your own, based upon the needs of your workers, the style of roof you have, the feasibility of installing certain types of protection, and, of course, the nature of the job at hand.
Your decision should be based upon your own observations of the fall hazards present during routine inspections. It's also vital that you consider the input and experiences of the workers who perform duties on the rooftop. Finally, you should always seek the recommendation of qualified safety professionals. Keep in mind that a solution you choose for now may not be adequate as circumstances change. That means you should be prepared to alter your course as needed.
This is a valid concern since your facility and its contents are a major investment. You may be concerned that installing guard railings, horizontal lifelines, or other roof lifeline systems will cause roof leaks that can damage the building. Fortunately, a non-penetrating roof fall protection system can provide workers with OSHA compliant protection and maintain the integrity of your roof. Therefore, there's no real excuse for not having the proper roof fall protection installed.
If your workers are expected to perform any duties on the rooftop, you need to be fully aware of the OSHA regulations under 1910.28(b)(1)(i) "Duty to Have Fall Protection." Providing adequate fall protection means making sure that you eliminate as many fall hazards as possible and minimize employees' exposure to those hazards that can't be eliminated. In part, the regulation states:
Except as provided elsewhere in this section, the employer must ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level is protected from falling by one or more of the following: Guardrail systems; Safety net systems; or Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems.
Even with the best fall protection devices, your workers are your most important tool in fall prevention. The best way to encourage safety is to lead by example and maintain a high level of focus on safety and your team will follow suit. Written safety procedures and protocols should be posted in prominent locations where all employees can see them. There's no substitute, however, for training and you should have a program in place to train new employees and to refresh the safety knowledge of your long-time employees as well.