Fall Protection in the Roofing Industry

1. Fall Protection in the Roofing Industry

2. SUBPART Fall Protection for Roofing M Overview • Relationship of Subpart M (Construction) with other OSHA fall protection requirements • Fall protection requirements in Construction, Subpart M specifically for roofing activities • Multi-employer citation policy • Q&A

3. SUBPART Fall Protection for Roofing M • Two approaches on safety for falls: • Fall Prevention– prevents employee from falling (e.g., guardrails, fall restraint systems, covers, skylight screens, warning lines, safety monitor) • Fall Arrest– safely catches employee after they have fallen and before they strike a lower level. (e.g., personal fall arrest systems, positioning device systems, safety nets)

4. SUBPART Fall Protection M 1st Question- Is the work being performed eitherinspection, investigation, or assessment prior to the start of construction work or after completion of the construction work?If it is, Subpart M does not apply and fall protection is not required during these activities.

5. Fall Protection Requirements SUBPART Fall Protection for Roofing M (Subpart M, 29 CFR 1926.500 – 503) • Most work 6 feet above levels to which you could fall (primarily based on type of work activity or exposure condition): • Ramps, runways, walkways, • excavations, hoist areas, holes, • formwork, reinforcing steel, leading • edges, unprotected sides or edges, • overhand bricklaying, roofing, • pre-cast concrete erection, wall • openings, residential construction, and • other walking/working surfaces.

6. Scope of Subpart M SUBPART Fall Protection for Roofing M • Subpart M is like the general duty clause for fall protection in Construction (i.e., it covers fall protection when not specifically addressed by another standard). • For example, it does not cover: • employees on: scaffolds (Subpart L); • personnel platforms on a scaffold, crane or mobile equipment; • stairways and ladders (Subpart X) • following activities: steel erection (Subpart R), towers & tanks erection(1926.104), electrical power generation, transmission & distribution (Subpart V)

7. SUBPART Fall Protection for Roofing M Fall Protection for Roofing Work Roofing Work is defined in Subpart M as: hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including construction of the roof deck. Subpart M covers fall protection for employees performing roofing work except when such employees are on equipment covered by another standard (e.g., scaffolds, personnel platforms, aerial lifts, stairways & ladders). Employees involved in roofing work on steel erection sites are covered by Subpart R when such roofing work is performed during and as a part of the steel erection work (roofing material must serve as a structural component, such as could occur with some standing seam metal roof installs).

8. Holes (501(b)(4))- 2” or moreMORE PEOPLE FALL THROUGH ROOFS THAN OFF OF THEM!!!! • Protection must be provided as soon as hole is created; protection prevents employees from tripping in or stepping into hole or falling into hole by either: • Cover over • Guardrail around • Personal fall arrest system (PFAS) for employees • Restraint system to keep workers away from fall hazard

9. Hole Cover RequirementsAlso must provide falling object protection if employees below SUBPART Fall Protection for Roofing M • Cover all floor, ceiling, or working surface holes, including skylights, that are larger than 2 inches. - Must support twice the weight of loads imposed at one time. - Secure from horizontal displacement. - Marked “hole” or “cover.” - Must cover hole as soon as created

10. Preventing Falls Through Roof Holes SUBPART Fall Protection for Roofing M Inadequate “cover” Skylights or larger deck holes can be covered, surrounded by barriers or have nets put underneath.

11. SUBPART Fall Protection for Roofing M Floor/Deck Hole Covers Secured? Clearly Marked? Capable of supporting 2X weight imposed?

12. Protecting Openings/ Skylights & Bad Decking • Skylights • Requirements • Must be protected with: • 3/4” Plywood Covers • Twice the expected load • Tables • Fall Protection • Skylight Nets • Guardrails

13. Protecting Openings/ Skylights & Bad Decking • Skylight Protection • Tables • Covers • Nets • Flagged off

14. SUBPART Hole Covers PersonalFallArrest Systems Guardrail Systems Canopies Warning Line Systems Safety Monitoring Systems Controlled Access Zones Fall Protection for Roofing M • For roofing activities, Subpart M breaks down the allowed fall protective measures (other than for holes) into two categories: • residential 1926.501(b)(13) • non-residential 1926.501(b)(10 & 11)

15. Either provide conventional fall protection; i.e., PFAS, safety net, or guardrails; or follow the alternative protective procedures allowed (to be presented later). For Non-residential roofing, alternative protective procedures are allowed only for low slope roofs (i.e., < 4:12). In other words, steep slope roofs require conventional fall protection ie. Guardrails, safety nets or personal fall arrest system. (501(b)(11)). Basic Criteria for Both SUBPART Fall Protection for Roofing M

16. Determining Slope The run will always be twelve (12) inches The following is an example of a slope measurement: Rise = 2" Slope = ------------------ Run = 12" 2" 12" In this example, the slope is 2 and 12

17. Low Sloped Roofs (4 and 12 or less) Any roof with a slope of 4 and 12 or less is considered low sloped. Greater than 4 and 12 is steep slope. The following fall protection systems can be used on a low sloped roof: • If < 50 ft width or less, then safety monitor alone is allowed (no mechanical equipment 502(h)(2)). • For >50 ft width, either: • Warning line and safety net • Warning line and guardrail • Warning line and PFAS, or • Warning line and safety monitor

18. Walkway to Work Area • Walkways must: • Have clear access • Protect against hazards • Designate area • Be reviewed with Crew

19. Guardrail System • Method of CONVENTIONAL FALL PROTECTION • Top rails must be between 39-45 inches high and withstand a lateral force of 200 lbs. • A midrail must be placed between the top rail and the work platform and be able to withstand a force of 150 lbs. • When using wire rope as a guardrail the following criteria must be met: • There must not be more than a 2 inch deflection when a force of 200 lbs. is applied against it in any direction • Top rail must be flagged every 6 feet • Must have a toeboard to prevent debris from falling off roof (if there is no parapet wall) • Must be a minimum of four feet on each side of a material handling area

20. SUBPART Fall Protection for Roofing M Guardrail Requirements • Subpart M (1926.502(b))

21. Manufactured Guardrail Systems This is one type of available guardrails for use on flat roofs.

22. Too much Sag?

23. SUBPART Fall Protection for Roofing M Toeboards Toeboards prevent tools or materials from becoming falling objects. Store materials minimum 10’ from edge. Add screen or mesh if tools or materials extend above toeboards.

24. Personal Fall Arrest Systems(PFAS) SUBPART Fall Protection for Roofing M • Method of CONVENTIONAL FALL PROTECTION • Components If one of these parts fails, the system fails.

25. PFAS Anchorage Requirements SUBPART Fall Protection M • Capable of supporting at least 5,000 pounds per attached employee or used as part of an PFAS that maintains a safety factor of at least ‘2’ (designed, installed and used under supervision of a qualified person). • Independent of any anchorage being used to support or suspend platforms.

26. SUBPART Fall Protection for Roofing M PFAS Devices Roof bracket Rope grab on a lanyard with deceleration device

27. SUBPART Fall Protection for Roofing M Sloped Roofing - PFAS Anchorages

28. SUBPART Fall Protection for Roofing M PFAS Devices • Limits fall to 2 feet or less • Must be attached directly to “D” ring on harness • Shock absorber may prevent lock up, or lead to ratchet effect. • Line must be protected from damage over edges. • Install and inspect in accordance with manufacturer; some will work horizontally,while some will not. Watch swing hazards! Self-Retracting Lifeline

29. SUBPART Fall Protection for Roofing M PFAS Devices Horizontal Life Lines- must be designed, installed and used under the supervision of a qualified person- maintain a minimum safety of factor of 2

30. PR600 Raptor

31. Please continue to Fall Protection Part II