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With snow and ice clearing from manufacturing facility rooftops, it’s time to assess spring-time rooftop maintenance needs. That means your roof fall protection systems must be in tip-top shape.
Even after the need for rooftop snow and ice removal subsides, OSHA regulations still require regular inspections and maintenance for any walking-working surface. Depending on winter storm severity, roof damage could include:
Breached roofing materials
Issues caused by pooling water and ice dams
Structural damage from heavy snows or snow removal equipment
Malfunctioning rooftop machines
Failed skylight seals
Damaged ventilation ducts and conduits
Bent flashing and other components along at the leading edge
Addressing these issues is important to withstand the coming spring rains and maintain efficient operations at your facility. Most important of all, a safe working rooftop environment is essential for worker safety.
Spring rooftop maintenance typically involves the largest number of hazards roof technicians will face all year. During that time, fixed rooftop fall protection equipment often inhibits safe and easy access across the roof's surface. Such devices can also cause rooftop damage themselves, both by penetrating the roof's surface and if they come loose.
If railing attachment points loosen, continual freeze/melt cycles during winter have likely already allowed water to work their way deep into the roof, expanding and contracting to cause further damage. When spring rains arrive, these breaches become vulnerable to further water damage.
By contrast, a modular, non-penetrating guardrail system is capable of meeting the same OSHA guardrail requirements for general industry (OSHA 1910.29[b]) while protecting the roof's surface from damage.
Modular railing facilitates much faster rooftop inspections. That's because there's a slight catch-22 to beginning rooftop maintenance after winter: how can workers safely assess the roof's condition without exposing themselves to the very issues, largely unknown, that they're there to address?
OSHA 1910.22(d)(2) requires correcting hazardous walking-working surface conditions before employees use them. Yet it also states:
"If the correction or repair cannot be made immediately, the hazard must be guarded[…] until the hazard is corrected or repaired."
Quickly guarding newly discovered rooftop hazards is critical at this time. Thus, the most reliable roof guardrails are those supporting fast deployment and adjustment.
For numerous hazards, modular roof fall protection systems are the most realistic and effective way to address weather-related rooftop hazards. As roof inspectors verify which portions of a roof are safe, they can place adaptable fall protection equipment where it’s most helpful. Per OSHA, that includes leading edges more than 4 ft (1.2 m) above the surface below.
Manufacturing facility fall protection should ideally include guardrails along an entire working rooftop's perimeter. If for any reason it doesn't (as for large areas not typically requiring work), modular railing can still protect workers from leading edges by positioning the railing closer to the roof egress point(s).
Moving gradually, rooftop inspectors can then move the perimeter of modular railing to make more area accessible while meeting compliance requirements. As they go, roof technicians must erect protection around a variety of hazards well within the roof's perimeter, including:
Interior openings of any kind, which require the same considerations as any leading edge 4 ft or above the surface below.
Skylights, where modular railing meets safety requirements for holes, as described at OSHA 1910.29(b)(11). Movable railing is often a superior alternative to covers (another option, per subsection [e]), because the former allows technicians to quickly access skylights without completely removing protective device(s).
Rooftop hatches, in which modular railing easily integrates with self-closing gates, which themselves must meet many of the same OSHA guardrail requirements (per OSHA 1910.29[b][13][i]).
Dangerous machinery. OSHA 1910.212(a)(3)(ii) requires guarding for any machine, lacking guards affixed to the machine, that presents point-of-operation injuries (e.g., rotating parts, nip points, high voltage, etc.).
Structural damage and tripping hazards, including torn roofing materials, protrusions, heavily corroded areas, and leaks (see OSHA 1910.22[a][3]).
By adapting to unique and varied conditions, modular roof guardrails can protect roof inspectors from hazards even before the full extent of those hazards is perfectly clear.
A retractable/folding rail system can be an even more ideal solution for rooftop damage requiring immediate protection and followup maintenance. Folding down in seconds, technicians can easily conduct maintenance or repair work, and then just as quickly redeploy the railing when complete.
These and other modular railing systems function perfectly in parallel with PPE, such as lanyards. For instance, it's possible to leave all but one section of railing up to facilitate single-technician access while still protecting each other side of the rooftop hazard.
Once springtime roof repairs commence, it's extremely important to know the dividing line between general industry maintenance and bona fide construction work. This largely depends on context, scale, and the nature of any rooftop repair.
During rooftop construction work, OSHA guardrail requirements (1926.501[b][1]) apply only to leading edges 6 ft (1.8 m) or more above the surface below. This enables technicians to arrange non-penetrating railing accordingly. However, determining the threshold between general industry (i.e. routine, anticipated maintenance that’s limited in scope) and construction work can be difficult.
While OSHA ultimately bases such determinations on a "fact-specific analysis" of each case, they advise that construction regulations typically apply in the following cases:
Demolition, i.e., the removal of most materials
"Extensive" repairs (including painting), taking into account the scale and complexity of each project
Removing and replacing rooftop equipment with "an improved type"
In such cases, the most reliable roof guardrails are those that function equally well in temporary and permanent capacities, and with no loss in safety or effectiveness.
Ensuring your manufacturing facility fall protection meets the correct legal requirements under any given circumstance requires thorough knowledge of your OSHA and CCOHS regulations. Always consult the regulations affecting your facility before adjusting your roof fall protection system.
Springtime roof maintenance tests the effectiveness of roof fall protection systems like no other time of the year. The first step in guarding your interests and your employees is investing in the most reliable roof guardrails on the market. Making the shift to modular, non-penetrating railing can dramatically improve manufacturing facility fall protection while providing maximum control over mixed rooftop hazards.
BlueWater is fully invested in protecting the interests of manufacturing facility stakeholders through more effective and adaptable roof guardrail systems. Contact us today and discuss your manufacturing facility's rooftop safety needs in full.
