As an employer, you’re obligated to provide a safe workplace for your people. And among your top priorities is fall protection for anyone working at heights of 4' or more. If an OSHA inspector were to enter your facility right now, they would want to see that you're using an OSHA compliant guardrail, gates, and other fall protection equipment where appropriate within your facility. And while you may also be using OSHA-compliant roof fall protection, it may not be so easy for the inspector’s to see at first glance.
In many cases, the scope of an OSHA inspection is somewhat limited. OSHA inspectors must follow the "plain view doctrine" when it comes to observing compliance issues. Inspectors and compliance officers are also restricted from putting themselves in danger in order to perform an inspection. Accordingly, they may avoid accessing areas which require special equipment or exposure to falling risk to enter.
In recent years, OSHA has approached the Federal Aviation Administration (FAA) for approval to use drones for more inspections, specifically to view areas on or near rooftops. As OSHA uses drones during inspections, there will certainly be implications for you and your business. Most notably, there could be an increase in the number of roof fall protection violations that are cited during routine inspections. But this may only be the start.
The main reason OSHA would want to use a drone to perform an inspection is safety. The roof of your facility, elevated surfaces, and other dangerous areas may not be readily accessible to an inspector. Because there are rules limiting an inspector's ability to climb ladders or to get to hard-to-reach places for observations, violations are often missed.
During a typical OSHA inspection, compliance officers are only allowed to report on what they can see themselves. So, if a hazard exists in an area that is difficult to reach or dangerous, it may not be found, reported, and corrected. This can pose additional dangers later. Some spaces this may apply to include ceiling spaces, areas inside machinery or equipment, ductwork, etc.
No, not yet. The vast majority of the inspections performed by OSHA compliance officers are done the traditional way. When an accident or incident happens, inspectors make a surprise visit to the facility, observe, document, fine, and penalize based on their observations. At the moment, OSHA typically only uses drones to perform inspections when it is too dangerous for people to enter the area, but that may change soon as the practice becomes more widely adopted.
In recent years, OSHA has begun to push the FAA to give it the ability to use more drones to perform inspections and to take photographs and videos of worksites with UAS. While the FAA hasn't officially ruled in favor of drones for OSHA inspections, they are becoming more common, but only when the employer gives permission. Otherwise, an inspector may have to seek a warrant to use a drone.
Like everything else in life, technology has an impact on the way compliance officers carry out OSHA inspections. Experts agree that it's likely that OSHA inspectors will increasingly use drones and other technology to perform inspections in the future. Instead of worrying about how OSHA inspections will be performed, it's more important to focus on OSHA compliance on all hazards, at all times.
You likely already understand that under OSHA 1910.28, you must provide protection against falls from heights. You also know that this is a requirement all the time, not just because drone inspections have been increasing. Remember that in general industry, you'll need to make sure you use an OSHA compliant guardrail system to protect elevated platforms and walkways, loading docks, uneven floors, and other places workers may access. In addition, you'll need to install rooftop safety rails for leading edge protection as well as for protecting roof openings.
To be compliant with regulations set forth in OSHA 1910.29, your OSHA compliant guardrail must meet the following criteria:
Be 42" tall (plus or minus 3") measured from the walking/working surface.
Capable of handling 200 lbs. of downward or outward force on the top rail without failing.
Midrails must be able to handle 150 lbs. of downward or outward force.
Roof guardrails, like other safety rails, must be made of smooth material that won't snag or scratch.
Toeboards must be installed when there is a risk of falling objects above machinery or people.
While the leading edge is arguably the most dangerous place on your industrial rooftop, it's by far not the only one. Any rooftop opening or significant change in elevation can pose a fall hazard on your rooftop, and they need to be addressed. Rooftop safety rails may be used for a variety of applications including:
Protecting roof openings and hatches
Providing protection for uneven rooftop surfaces
Preventing people from walking on skylights
Marking holes and other trip hazards on the roof
Guarding rooftop machinery and equipment
Although installing an OSHA compliant guardrail system on your rooftop may seem like the best way to remain compliant with the regulations, it may not be enough. Remember that roof guardrails aren't always feasible for every application. In addition to safety rails, you may want to incorporate other fall protection equipment to ensure your workers are safe.
Seek the advice of a qualified safety expert who has experience dealing with protecting workers on rooftops. Some of the equipment you may need includes:
Industrial swing gates to limit access to restricted or dangerous and hazardous areas
Personal fall protection devices such as a body harness, lanyard, and lifeline
Skylight screens, roof hatches, and other roof opening covers that are OSHA-compliant
Ladder safety systems, safety railings and other fall protection for roof access points
Want to be ready for in-person or drone-based inspections? Not sure what type of roof fall protection is right for your building? To learn more about OSHA-compliant, customizable roof guardrails for industrial facilities contact BlueWater today and one of our qualified safety experts will be happy to discuss your fall safety needs and concerns. We'll help you find the right fall protection equipment to keep your workers safe and your company compliant, no matter how OSHA inspects your building.
