Fall Protection on Low Sloped Roofs for General Industry Presented by: Brian Stickler
Learning Objectives: Learn how to identify hazard areas on the roof Determine what OSHA considers to be a hole on the roof Recognize how to keep your employees and contractors safe on the roof State what a safe distance is from the edge of the roof
What motivates you when you go to work? Position Prestige Money Family Importance
Who is performing the work? Contractors Maintenance Staff
General Industry or Construction? OSHA s regulations define construction work as construction, alteration, and/or repair, including painting and decorating. Maintenance means keeping equipment or a structure in proper condition through routine, scheduled or anticipated measures without having to significantly alter the structure or equipment in the process. Whether the work is performed in-house or by an outside contractor is not a factor. Link to Standard Interpretation: http://www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=interpretations&p_id=24789 Source: Flat Roof Final 27 Feb 2015 Update PPT Presentation by Richard Brown US DOL OSHA
How Far from the roof edge is safe? As discussed in the Preamble to Subpart M in volume 59 of the Federal Register (page 40683), OSHA determined in the rulemaking that there is no safe distance from an unprotected side or edge of a walking/working surface that would render protection unnecessary. Link to Standard Interpretation: http://www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=interpretations&p_id=24802 Source: Flat Roof Final 27 Feb 2015 Update PPT Presentation by Richard Brown US DOL OSHA
Hierarchy of Fall Protection Engineering Controls: Remove Units from Roof or Eliminate Completely Collective: Guardrails Fall Restraint: Dog Leash Fall Arrest: Fall occurs, landing does not Engineering Controls Passive Fall Restraint Fall Arrest
Where do we start? How is the roof Accessed? Fixed Ladder or Stairs Walk Out Roof Hatch
1910.23(a)(2) Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.
1910.23(a)(3) Every hatchway and chute floor opening shall be guarded by one of the following:..1910.23(a)(3)(i) 1910.23(a)(3)(i) Hinged floor opening cover of standard strength and construction equipped with standard railings or permanently attached thereto so as to leave only one exposed side. When the opening is not in use, the cover shall be closed or the exposed side shall be guarded at both top and intermediate positions by removable standard railings. 1910.23(a)(3)(ii) A removable railing with toeboard on not more than two sides of the opening and fixed standard railings with toeboards on all other exposed sides. The removable railings shall be kept in place when the opening is not in use. Where operating conditions necessitate the feeding of material into any hatchway or chute opening, protection shall be provided to prevent a person from falling through the opening.
Second Easiest area to protect HATCHES
1910.23(a)(4) Every skylight floor opening and hole shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.
Third Easiest area to protect SKYLIGHTS
OSHA 1910.23(c)(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder.
Separating People from Hazards
Are there any other ways to comply with OSHA 1910.23? Yes!
General Industry 2010 Proposed Subpart D Under OSHA s policy for de minimis violations, in place of complying with an existing standard an employer may comply with a proposed standard or amendment that clearly provides equal or greater employee protection. Link to Standard Interpretation: https://www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=interpretations&p_id=25303 Source: Flat Roof Final 27 Feb 2015 Update PPT Presentation by Richard Brown US DOL OSHA
Designated Areas 1910.29(d)(1) Employees remain within the DA while work operations are underway The work be of a temporary nature, such as maintenance on roof top equipment Uprights must be erected as close to the work area as is permitted by the task The perimeter of the DA must be erected at least 6 feet from the unprotected side or edge.
General Industry 2010 Proposed Subpart D Another de minimis violation, would be Personal Fall Arrest Systems Anchor Points Fall Arrest Fall Restraint Link to Standard Interpretation: https://www.osha.gov/pls/oshaweb/owadisp.show_document? p_table=interpretations&p_id=25303 Source: Flat Roof Final 27 Feb 2015 Update PPT Presentation by Richard Brown US DOL OSHA
Separating People from Hazards Wrap Up Protect Ladders w/ Railing and self-closing gates Protect Roof Hatches with Railing Protect Skylights with Screens or Guardrails No safe distance from the edge Use Guardrails and Designated Areas Use Personal Fall Arrest Systems
Separating People from Hazards 614 Stop by our booth to talk more about Warning Line Use in General Ind. Anchor Points in General Ind. Rooftop Safety Audits
Separating People from Hazards