From oil refineries and food processing plants to higher education and manufacturing facilities, workers must frequently accomplish work at height. Rooftops especially carry a large cross-section of fall hazards, invoking a slate of OSHA rooftop safety standards. How can general industries fully meet their duty to have fall protection, avoid fines by staying compliant, and even sharpen their competitive edge?
Because commercial rooftops are inherently varied, safety rail systems should support an equivalent level of adaptation. This means accommodating a unique and varied assortment of:
Utility pipes and conduits
Ventilation ducts
Hatch openings
Skylights
Parapets and ledges
Rooftop equipment
Exterior stairways
While it may seem each of these challenges requires its own custom treatment, advancements in rooftop guardrail systems have expanded the capacity of business owners and safety managers to fulfill a large share of occupational hazards with minimal effort.
These considerations go beyond leading-edge protection. Rooftops also have a host of tripping and machine hazards that require barriers designed to repeatedly withstand the force of falling bodies, objects, and mobile maintenance equipment. For these and other reasons, industry leaders across numerous verticals are finding the best guardrails can be found in versatile rooftop guardrail systems and are making the shift.
OSHA rooftop safety reflects multifaceted and varied conditions – and while federal safety regulations don't "prescribe" or certify any specific equipment make and model, they do outline device force ratings and dimensions that you can use when finding the best guardrails for your needs.
Getting these basics down is extremely important to simplify your comparison of safety rail systems and ensure they meet all necessary standards. At a time when OSHA is placing extra scrutiny on rooftop safety, it's necessary to ensure your passive fall protection equipment doesn't limit your ability to meet the widest possible range of rooftop safety regulations.
Note the following guardrail standards come from OSHA 1910.29(b), which covers general industry fall protection on federally regulated rooftop environments:
A continuous, smooth surface to prevent snagging workers' clothing or PPE
Top edge of safety rail systems must be between 39 in. (99 cm) and 45 in. (114 cm) from walking-working surface, and capable of withstanding at least 200 lbs (890 N) of downward/outward force without deflecting less than 39 in.*
Midrails spaced evenly between walking-working surface and top edge of railing, and capable of withstanding 150 lbs (667 N) of force in a downward and outward direction
Top and midrails at least 0.25 in. (0.6 cm) in diameter, and which don't present projection hazards in working areas
Intermediate members (including panels, mesh screens, and vertical rails, but excluding plastic or steel banding) between walking-working surface and top edge of guardrail system (except over parapets 21 in. [53 cm] high) – any of which requires the same force ratings as midrails
Intermediate vertical members (e.g., balusters) at least 19 in. (48 cm) apart
*Note the force-deflection standard gives little-or-no margin for top guardrails at or near the minimum height. That's why a top rail height of 42 in. (107 cm) is the de facto standard.
If you have active rooftop construction, you'll need to simultaneously heed OSHA 1926.502(b). Generally, guardrail design standards are the same – what differs is primarily their application.
See this OSHA online training blog for clarity on the difference between general industry vs construction, which levels the primary differences down to:
The height at which fall protection applies
Whether the work involves confined spaces
When and which PPE requirements apply
Additional safety requirements for ladders
Distance to eyewash stations
Illumination requirements
Signage standards for temporary hazards
There's also some gray area regarding when OSHA considers a task strictly construction vs maintenance. In practice, they've assessed the difference with regard to a simple two-part litmus test:
Keeping equipment "working in its existing state" (not falling into disrepair, i.e.) is maintenance; this includes basic replacements
Work aimed at "improvement" is considered construction; though the scale of work can also be a determining factor
So how do you know exactly when OSHA 1926.502 kicks in, and when OSHA 1910.29 is sufficient?
There's simply no shorthand for knowing your industry's OSHA, CCOHS, or local "state plan" standards inside and out, and keeping yourself informed of updates. Fortunately, a modular guardrail system from long-standing industry experts will meet the widest range of ever-changing fall hazards, work conditions, and regulatory standards.
As you can see, compliance depends not only on work location, but the type of work involved. Once you've carefully determined the proper jurisdiction and definition for any rooftop work, you'll also need to continually gauge how your workflows affect the positioning of your safety rail systems.
OSHA takes great pains to describe which working-at-height conditions invoke general fall protection standards. This includes "walking-working surfaces," being any working surface at least 4 ft (1.8 m) above the next lower surface.
OSHA 1910.28 outlines walking working surfaces in greater detail. On rooftops, the most common walking-working surfaces include:
A roof's leading edge along the outer perimeter, including stairways
Elevated, open-sided platforms (such as mezzanines to access tall rooftop equipment or temporary scaffolding during construction)
Interior openings (including skylights and hatches)
For all purposes, skylights are treated exactly the same as holes, which can be protected with guardrails in the same way. OSHA 1910.29(b)(11) requires protection, most often achieved with guardrails, around all exposed sides/edges of a hole.
As for hatches, they must be treated as an interior opening no matter how briefly the hatch cover is actually open. The hatch guardrail/swing gate systems must comply with OSHA 1910.23(d)(9) and 1910.29(b)(13), which set spacing and clearance standards for the hatch opening, ladder termination points, the railing, self-closing gates and more (swing gates essentially follow the same standards for guardrails, described above). Similar standards also apply to stairway access points.
Be advised fall hazards also encompass tripping and dangerous equipment hazards. Rooftops often have large commercial HVAC devices, transformers, and sometimes even telecom equipment. These devices can create cutting, crushing, or electrocution hazards.
Even so much as a small ledge at transition points can present tripping hazards, so it's best to demarcate them for easy visibility. Remember that duty to have fall protection isn't limited to working at height.
How can property owners and safety managers select the best guardrails for their unique array of safety hazards – and without compromising long-term budgets or safety requirements?
Modular, non-penetrating safety rail systems can mitigate nearly all the OSHA rooftop safety concerns contemplated above and protect your company from fines. Traditional, fixed-installation guardrails are incapable of adapting to workflows, and because they penetrate rooftop materials, they present maintenance risks that could degrade the walking-working surface over time.
In virtually all cases, it's best to adapt your passive fall protection strategy around your workflow and shifting regulatory standards – not the opposite.
Modern rooftop guardrail systems can even accommodate architectural considerations. Folding rail systems enable easy deployment during rooftop operations, then fold neatly down to preserve your building's architectural profile. There are also more stylish custom guardrail designs with visually appealing curves and angles, and it's possible to customize color using functional, non-toxic powder coating.
With the most innovative passive fall protection solutions, there's no reason to see OSHA rooftop safety as somehow at odds with your general workflow or aesthetic concerns. In fact, you can enhance them all the more by modernizing your rooftop safety strategy.
More than ever, commercial rooftops in virtually all industries need easy, reliable, and cost-effective fall protection solutions. Getting your business on the right side of the rule book is much faster and more effective by working with a specialist with decades of experience engineering safety rail systems for the widest range of working-at-height challenges.
Above all, choose the most ideal rooftop guardrail system for your industry and scope of work. Contact BlueWater – a trusted brand in fall protection with partners across numerous high-risk industries – for more information on to develop a rooftop safety strategy for your facility.
