It can go without saying that fall protection systems—and fall protection in general—are a big priority for OSHA. Not only can falls be incredibly dangerous for workers, after all, but the situations in which workers risk falling are incredibly common. If you need an example, consider the risks of rooftop maintenance tasks and construction (not to mention façade access or telco repair projects).
In 2024, OSHA released new data that shows a diligent focus on fall risks is working: both state and federal OSHA records show better fall statistics than in previous years This good news underscores how important it is to invest in adequate roof fall protection systems and protocols to keep workers safe and comply with OSHA's continued focus on fall-related safety.
If you're not sure where to get started meeting OSHA guardrail requirements, begin with these three core things you need to know to stay OSHA compliant.
Every building is different, and while there are standardized tools and solutions for mitigating potential fall hazards, the specific layout of your buildings' rooftops will determine which solutions you need (and how many of them you need). Whether you're building a brand-new OSHA compliance and fall protection program for a new facility, or you want to review and revise your existing programs, it all starts with a thorough assessment of your building.
Inspect your commercial rooftop for these and other roof hazards:
Unprotected leading edges: These edges might be completely unguarded, have incomplete warning lines that visually identify the hazard, or feature only partial installation of physical barriers that prevent falls. Barriers that fail to meet OSHA guardrail requirements can be almost as dangerous as no guardrails at all.
Edges that aren't the main edge of the roof: This could include raised platforms, different surfaces of a complex roof style, oversized machines, and so on. Any change in elevation of six feet or more needs to be considered.
Temporary openings: This is common on construction sites, where openings and safe pathways are constantly changing as the project progresses. However, even complete buildings may be undergoing renovations, have new hatches, or have corded-off areas where the rooftop has sustained damage.
Trip hazards: Trip hazards include ductwork, vents, stairs, and sudden but small changes in elevation. Depending on your region, some surfaces may also be more susceptible to frost or water pooling, which increases the risk of slips and falls.
Hatches: Ladder hatches, stairwells, and other changes in elevation represent a major risk because they might be as visually apparent as the edge of the building.
We recommend creating thorough records of both the existing hazards that you suspect don't comply with OSHA regulations and all of the rooftop areas that must comply with OSHA regulations. The first record will tell you priority areas, and the second will be the foundation for any internal audit programs you create so you can assess and ensure compliance in subsequent years.
The first thing you needed to know was where your organization might be failing to comply with OSHA standards regarding rooftop fall protection. Now, it's time to identify where your organization is currently failing to comply. Create a thorough internal audit of how your company has addressed or resolved all the hazards you flagged in the first section. Consider:
Attempts at fall protection systems and hardware that fail to meet OSHA guardrail requirements and other standards: Some equipment, barriers, and visual signs fall short of OSHA's requirements. Replace these hazards with modernized equipment and installation so workers can trust them.
Poor training: Training is a critical aspect of OSHA fall protection. All workers need to know how to properly use active fall protection systems like harnesses, the meaning behind different visual warning systems and signs, and how to give your safety team feedback.
If you have adequate passive fall protection and active fall protection: In many environments, you need both. Passive fall protection systems include barriers, rail systems, non-penetrating guardrail installations, and gates that are always standing by to block personnel from falling over an edge. This category also includes a roof warning line system that marks edges and hazards. Active fall protection includes harnesses and lifelines for either catching workers if they fall or allowing workers to perform tasks while suspended in the air.
Be diligent and check to ensure the fall protection systems you have comply with the details of the standards. It's not enough to simply have equipment—it needs to be the right equipment.
Your first internal audit is a great resource, even (or especially) if it shows poor results. Now, you have baseline documentation that highlights exactly what changes you need to make. You can also schedule repeat audits monthly or quarterly so you can measure improvements over time. Once you have the information you need, you can implement changes through a couple of different strategies:
Start simple: Identify the compliance issues that are simplest or fastest to solve, such as readjusting your roof warning line system, replacing barriers with OSHA-compliant barriers, and updating your safety signage. This has a snowball effect and can help your team see quick results that build momentum.
Start with high-priority items: If your audits revealed dangerous compliance gaps that pose severe injury risks, start there. This might include investing in new fall protection harnesses, closing leading edge gaps that have no non-penetrating guardrail systems at all, and installing new anchor points to replace treacherous installations.
The right strategy will vary based on your building, culture, executive buy-in, and budget. However, adopting a methodical approach offers your whole organization several benefits. For example, while proper roof fall protection systems such as better roof fall protection guardrails or new fall protection systems for hatches may have been outside of your initial budget, the audits will demonstrate both the need for the purchase and the immediate compliance benefits. Making methodical changes also breaks down large safety overhauls into clear steps.
Along the way, provide training and implement information campaigns. Educate your staff about the new equipment, how to use it, and the benefits it provides them. Not only is training part of OSHA compliance, but it can also propel staff into using the equipment more readily and adopting safer practices.
Bluewater specializes in providing commercial and industrial organizations with OSHA-compliant roof fall protection systems. Our active and passive fall protections comply with several of the OSHA, CCOHS, and local regulations your safety team needs to account for, and we provide resources to help you conduct organized safety audits. Our solutions include non-penetrating guardrail solutions, compliant roof warning line system products, harnesses, and more. Reach out today to learn more about what you need to know to stay OSHA compliant or browse our products to make your first big changes.
