Stay OSHA Compliant During Winter Roof Maintenance with Safety Guard Rails

When winter arrives, it's easy to think that having a roof fall protection system — like safety guard rails — isn’t a top priority. After all, outdoor work slows significantly in the colder months. The truth is, there’s plenty of reasons your workers may need to get out on the roof this winter, and you’ll want to play safe — no matter what the weather may bring.

Changing weather conditions can affect roof areas in unpredictable ways. Severe storms may dump several inches (and pounds) of heavy snow, frozen dams can pond water, and high winds can strip away exterior layers. There’s a good chance your employees or contractors will need to visit the roof after a heavy storm to assess the damage. Since snow can easily disguise hidden dangers like icy patches, debris, and skylights, having a game plan can really save the day.

 Four Winter Hazards To Consider

Before we get started, here’s a quick look at the hazards winter brings to your rooftop.

• Ice Dams: this happens when a ridge of ice forms on the edge of a roof and prevents melting snow from draining. It can push and lift flashings and cause a host of problems.
• Heavy Snow:  Heavy snow is a major threat, and snowdrifts formed by wind can exacerbate the problem by unevenly distributing weight and cause your roof to collapse.  Additionally, snowdrifts may hide dangers and debris that people can trip over and fall.
• Expansion and Contraction: Roofs expand and contract in changing weather conditions. Cold temperatures shrink sealants, which causes cracking and deterioration, and may cause critical components like flashings to separate.
• Condensation: The heat from your building can cause condensation on your rooftop, which can soak back into your shingles. Condensation can rot materials, leading to mold, structure failure, insects — even vermin.

It’s Not Too Late: Preparing Your Roof for Winter

While autumn is the ideal time to get your roof ready for winter, you still have time to get out there before the heavy-hitting storms come to pass. Here are six things to think about:

1. Schedule an annual inspection for your rooftop.

To ensure your roof remains OSHA compliant, have it inspected at least once a year, ideally, twice, to stay on top of any maintenance issues that could be exacerbated by inclement weather.  If a severe winter storm hits, you should also have trained staff or professionals to inspect the area for damage.

During the inspection, your contractors should:

a.) Inspect all parts of your roof.

• Check the area for corrosion issues.
• Identify missing fasteners and damaged laps.
• Look for soft spots and wet insulation.
• Search for seam problems (including missing sealant).

b.) Search for leaking areas on every parapet wall, facade, or adjacent surface.

• Check for worn mortar joints.
• Locate and fix any deteriorated materials on your roof.
• Search for missing window gaskets.
• Get all repairs done correctly using the original manufacturer's instructions and recommended products. Your roof warranty likely requires that you maintain the area on a regular basis.

2. Order maintenance checks for all rooftop equipment.

Next, you'll need to have all rooftop equipment inspected to make sure it's working properly.

Schedule a maintenance check for your Heating, Ventilation, and Air Conditioning (HVAC) equipment. HVAC can create roofing problems when its liquid leaks onto your roof. This equipment needs protection since it has sharp panels that can damage your roof's membrane.

During the maintenance check, your contractor should:

• Make sure that your stacks vent properly.
• All condensation from HVAC should flow directly into a drain.
• Contaminants that end up on the surface should be handled by a catchment system or sacrificial membranes.
• Always follow the manufacturer's instructions when using the equipment.
• Have the contractor ensure that all HVAC screws are mounted correctly.

Have your roof fall protection system checked for any damage or problems. Make sure that your rooftop safety railing is in good, working order. OSHA asks employers to use systems that prevent falls over edges of buildings. See CFR 1926.501(b)(2). These include:

• Safety Guard Rails – Look for safety guard rails that meet or exceed OSHA regulations 29 CFR 1910.23 and 1926.500 – 1926.503.
• Skylight Rails – Skylights are dangerous — even more so when you can’t see them thanks to snow. Having a roof fall protection system like skylight rails help your workers identify where they are, and keep them from falling or tripping through.

 3. Hire a professional to clear debris from your roof and drainage system.

Trash, leaves, and other debris can block scuppers and drains. The water can pond, creating additional weight on your roof. All of this can be compounded by the presence of ice and snow. Get a professional on your roof to clean it up ahead of time and save yourself a headache down the road.

4. Eliminate and mark potential roofing hazards before winter arrives.

According to OSHA Standard 1926.501(a)(2), "employers shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely." Before snow hits, eliminate all hazards from the roof area and use flags to mark any hazards that snow can hide. Flagging dangers will make roof-related work safer for your employees. When snowstorms hit, remove snow from walkways, curbs, and skylights to prevent employees from tripping over them.

5. Educate employees about snow-related hazards.

Companies should tell workers about potential hazards caused by snow before they consider setting foot out on the roof. Make sure that your employees receive the required OSHA training about roof area hazards as well as how to use your roof fall protection system correctly.

6. Place all roof-related documentation in a single file for any future OSHA inspections.

This tip really is relevant year-round, but it’s worth the reminder. Your company can stay OSHA-compliant by keeping an updated roofing file. It should have the following information:

• The installer's contact number
• Installation plans and specs
• Roof-related warranties
• Rooftop safety railing installation and warranty information
• Dates for roof repairs
• Invoices for all roof-related repairs
• Maintenance and inspection reports

7. Have a plan in place in case there is an accident.

Hopefully, you’ll never have to use it. But having an action plan in place saves critical minutes if a fall does occur.

Protecting Your Roof and Your Workers During Winter

According to OSHA, employers must identify potential snow removal tasks on rooftop areas. To remain compliant, it’s in your best interest to have a snow-removal plan in place. Since snow makes rooftop work more precarious, your plan should include these OSHA tips.

1. Prevent falls during the snow removal process.

High winds and icy surfaces are an obvious mix for a slippery situation. To protect your workers, you should:

• Remove snow without requiring your employees to walk on the roofs. Try using snow rakes and draglines from below whenever possible. Your employees can also apply de-icing materials using ladders or aerial lifts. (See more on this below).
• Calculate the load bearing on the structure. OSHA recommends employers perform several safety checks before allowing workers on to the roof. Always tabulate the total weight of workers, snow, and equipment your roof can uphold without collapsing. This may even include the weight of your rooftop safety railing.
• Remain cautious when working on roof structures. Tell workers to utilize the roof guardrail as they navigate around the perimeter and to pay attention to any sounds or trembling that may signal that the structure is compromised.

2. Require all employees to use fall protection equipment when working on icy roofs.

According to OSHA standards, employers must identify each winter-related hazard workers can face on elevated construction sites of 6 feet or more (1926.501). The same requirements apply to non-construction sites 4 feet or higher.

• Remove or clearly mark rooftop hazards that can cause your employees to trip.
• Provide a roof fall protection system, such as a roof guardrail or personal fall protection harness, for employees that must remove snow in areas not adequately protected by a guardrail system. Require them to wear personal fall protection equipment. See 1926.501 (b).
• Educate workers about fall hazards when working on roofs. Only allow trained workers who know how to use fall protection equipment as mandated by OSHA standards 1910.132(f)(1) and 1926.503(a)(1).

3. Ensure workers use ladders and aerial lifts safely.

If you choose to use a ladder or aerial lift, keep in mind they come with their own set of safety issues. OSHA advises workers not to use a shovel or snow rake while on a ladder. Using these tools can cause people to lose their balance and fall. Make sure the ladder has secure footing, check all rungs for ice and snow, and clean all snow from shoes or boots before climbing the ladder.

Aerial lifts are a great way to carry snow rakes, shovels, and other de-icing equipment. Remember, OSHA standards 1910.67(c)(ii) and 1926.454 require employers to train all workers to use lifts before they start using them. Workers should also operate snow removal equipment at reduced speeds in slippery conditions.

Even though a heavy dose of snow can cause a lot of headaches, having a plan in place makes it a lot easier for everyone involved. Taking precautions ahead of the storm can be even more helpful.  Keeping rooftops free from debris and having a roof guardrail installed is a great start. If you need some extra help keeping your roof safe for the season, feel free to give a us call.