Unusual Rooftop Fall Protection Challenges for Pharmaceutical Manufacturing Facilities

Rooftops are among the most dangerous places for employees, no matter what type of facility you operate. Protecting workers from hazards like the leading edge, ladder and stair openings, rooftop hatches, and skylights is always a challenge. Pharmaceutical manufacturing facility rooftops, however, are a bit more complicated. While basic fall safety concerns must be addressed, safety managers and other leaders need to focus on the unusual challenges they face when choosing rooftop fall protection systems for maximum rooftop safety.

OSHA Requirements for Rooftop Fall Protection

Every employer, regardless of industry, has a duty to provide fall protection for their employees per OSHA 1910.28. This rule applies whenever people are working at a height of 4' or more above the level below for general industry. A pharmaceutical facility’s rooftop most certainly meets these criteria, meaning fall protection is essential. In fact, there are several areas on the roof that pose a fall hazard or that may represent a falling object hazard to those below.

Common Manufacturing Facility Rooftop Fall Hazards

Pharmaceutical manufacturing facility rooftops, like other types of facilities, are dangerous places for workers. The number and types of fall hazards present in this environment means special attention must be paid in order to mitigate the risks. A few of the areas that need to have fall protection installed include:

  • Rooftop Leading Edge - This is the most obvious rooftop fall hazard and the perfect opportunity for a passive fall protection system like metal guard rails. Installed around the perimeter, this type of roof safety system warns and protects workers. When a guard rail can't be used, warning lines and personal fall protection equipment may be necessary to keep workers safe.

  • Stairs and Ladders - Accessing the rooftop is imperative for equipment and rooftop maintenance, repairs, and other activities. Stairs and ladder ways need to be clear of debris, well-lit, and protected with handrails and/or safety gates. To restrict access and protect workers, other rooftop safety equipment such as a swing gate may also be necessary.

  • Roof Hatches and Other Holes - Access points like hatches allow maintenance and repair workers quick access to equipment on the rooftop from inside the building. When the hatch is open, it's a fall hazard and there's a risk of objects falling inside the hatch. Openings in the rooftop must be protected with a roof safety system like metal guard rails, swing gates, or other OSHA-compliant rooftop safety equipment

  • Rooftop Skylights - Natural lighting has many benefits in the workplace and skylights are often incorporated into the rooftop. While the light they allow in makes for a nicer workplace inside, they pose a risk to workers on the roof. OSHA-compliant skylight protection like a skylight guard rail helps minimize the chance a worker walks on or puts equipment on a fragile skylight.

Unique Rooftop Fall Safety Challenges for Pharmaceutical Facilities

In addition to the concerns noted above, manufacturers of pharmaceutical products require specialized equipment not found in other industries. From filtering systems to security, the biggest rooftop fall hazards you should be concerned with include:

  • Rooftop Machinery and Equipment - The best place for a building's HVAC system and other equipment is on the rooftop. This is also the case for pharmaceutical facilities, however, additional proprietary equipment such as filtration systems are also present. Metal guard rails or other roof safety systems protect valuable equipment and keeps workers from getting too close.

  • Security and Surveillance Systems - A key component to any pharmaceutical manufacturing facility is security. From protecting trade secrets and processes to providing security services for researchers and workers, the rooftop is a vital part of the plan. Cameras and other surveillance equipment need to be regularly serviced, however, and fall protection must be provided to the workers who do so.

  • Fire Suppression Equipment - Due to the volatile nature of some chemicals and processes, pharmaceutical companies need on-site fire suppression equipment. The rooftop is, as you'd expect, the ideal location for this equipment, but it also poses a high risk for workers and needs to be protected. Generally, a guard rail and safety gate are recommended, however, that depends on your rooftop and your work/maintenance crew.

 

OSHA Requirements for Rooftop Safety Equipment

One of the difficult things about staying compliant with OSHA regulations is that they don't always give you a specific prescription to follow. For example, there is no requirement for you to use a specific type of roof safety system to provide rooftop fall protection. You can choose whether you want to use a guard rail system, warning lines, personal fall protection devices, or a combination. What OSHA does do, however, is give you guidelines for each type of equipment such as:

Metal Guard Rails

If you choose to install safety railings to protect workers on your facility's rooftop, make sure that they meet the following:

  • Top railings must be 42" (+ or - 3") above the working/walking surface.

  • Safety railings have to handle a force of 200 lbs. without failing or deflecting below 39".

  • Midrails have to withstand at least 150 lbs. of force without failure.

  • Guard rails must be made of smooth material that won't snag or scratch workers.

Industrial Swing Gates

To provide access to restricted areas on the rooftop, metal swing gates are often paired with a guard rail system. 

  • Guard rails must meet the same height criteria as the metal guard rails noted above.

  • Strength requirements for safety gates are also the same as for railings.

  • Like guard rails, gates must be smooth so as not to injury or hinder employees.

  • Swing gates must open away from a hatchway, hole, or other fall hazard.

Warning Lines

In some cases, a guard rail just isn't appropriate fall protection. Perhaps the slope of the roof is too great, or the architecture of the building doesn't allow for a guard rail. Warning lines may be used then as long as:

  • The warning line has a minimum breaking strength of 200 lbs.

  • Extended warning line ropes can't sag below 34" or above 39" from the walking surface.

  • The warning line must be visible from a distance of 25' away.

  • Warning lines are installed no less than 6' from the edge.

Personal Fall Protection

In addition to passive roof fall protection systems like guard rails and warning lines, your employees may need additional personal fall protection devices. Lanyards, body harnesses, and lifelines, when provided, must meet OSHA 1910.140 requirements including: 

  • Harnesses and lanyards must be inspected before each use for signs of wear, damage, or defects.

  • Lanyards, lifelines, connectors, and anchors must have a minimum breaking strength of 5,000 pounds.

  • Personal protective equipment must be inspected by a qualified safety expert. 

  • Workers must be properly trained on how to use personal fall safety equipment.

 

OSHA-Approved Fall Protection Products and Advice

Keeping your pharmaceutical facility's employees safe when on the rooftop is your obligation, but it's not easy. There's a lot going on up there, and you need the help of a safety expert with experience dealing with fall safety issues in pharmaceutical manufacturing facilities, so you make the right decisions for your organization and your workers. Contact the safety experts at BlueWater today, and we will work with you to develop a plan to improve the rooftop fall protection at your pharmaceutical manufacturing facility.