According to the National Census of Fatal Occupational Injuries in 2019 published by the U.S. Bureau of Labor Statistics (BLS), approximately 5,333 fatal work injuries were recorded in the United States in 2019. That means that a worker died every 99 minutes on average from a work-related injury. The four occupations with the highest fatal injury rate were fishing and hunting workers, logging workers, aircraft pilots and flight engineers, and roofers. Even more alarming is that roofing contractors had a work fatality rate more than 10 times the average rate of work fatalities per year in 2019.
This equates to a fatal injury rate of 54.0 per 100,000 full-time equivalent workers when compared to the average rate across all occupations of 3.5. To put it into perspective, farmers, ranchers, and other agricultural managers saw a rate of 23.2 work-related fatal injuries per 100,000 full-time equivalent workers in 2019. As to the cause of these preventable work-related injuries and fatalities, look no further than the Occupational Safety and Health Administration’s (OSHA’s) Top 10 Most Frequently Cited Standards of 2019.
For the ninth year in a row, “Fall Protection, construction” was named the most frequently cited standard following inspections of worksites by federal OSHA for the fiscal year 2019. In this comprehensive guide, we’ll be reviewing everything you need to know about making your rooftops safe and accessible for your workers. For a roofing attorney who can help you understand the OSHA fall protection regulations, create a fall protection plan, review your company for compliance, and more, get in touch with Cotney Construction Law.
Roof Access Walkways
In this guide, we’ll be going over some of the most reliable ways to improve OSHA roof safety, meet industry requirements, and avoid work-related injuries and fatalities on your roof. To begin, we want to discuss roof access walkways — one of the primary means of ensuring safety on top of a commercial roof. Essentially, a roof access walkway, also known as a rooftop walkway or rooftop walkway system, is a pathway that allows people to traverse the roof in a safe manner. Although they can be made of various materials, they are typically made of rubber so that they may stick to rooftops or metal for non-slip purposes.
These walkways are incredibly beneficial because they encourage workers on your jobsite to take a clearly marked path away from hazards. The workers still have a great view to inspect the roof and place to rest atop the roof with non-penetrating fasteners that protect the membrane, and you have peace of mind knowing your workers are protected. A roof that’s easy to walk on also means safer access to pipes and other equipment, minimizing your worker’s risk and giving them the confidence to perform their job safely each day.
Related: 7 Varieties of Roof Safety Systems
Next up, guardrail systems. Also known as standard railings, this type of roof safety equipment is required for all platforms 4 feet or more above the adjacent floor or ground level. This includes mezzanines, loading docks, hatches, roof edges, and more. Generally speaking, the edge height of top rails or equivalent guardrail system members must be between 29 and 45 inches above the walking/working level. They must be able to withstand at least 200 pounds of force applied within 2 inches of this top edge and must not have any rough or jagged edges that would somehow cause lacerations, punctures, or snagged clothing. Midrails, mesh, intermediate vertical members, or other equivalent intermediate structures must also be installed between the top edge and walking/working surface when there is no wall or other structure at least 21 inches high.
In circumstances where the installation of a guardrail is necessary, feasible, and practical, there are three different styles of guardrails available:
- Non-Penetrating Guardrails: Non-penetrating guardrails, as their name suggests, can be installed without penetrating or otherwise making holes to the mounting surface. These base systems are easily assembled and disassembled and allow for easy transportation and set-up.
- Fixed Base Guardrails: Fixed base guardrails are permanent systems put in place to last the entire extent of the project. They’re commonly used for frequently accessed or hazardous work areas, such as loading docks, parapet walls, roof decks, and pits. Their mounting brackets can be attached either vertically or horizontally to wood, steel, or concrete.
- Portable Construction Guardrails: Finally, portable construction guardrails come in both temporary and permanent configurations and are mostly used on flat, parapet, or overhanging roofs. They’re lightweight, considerably easier to transport than steel or aluminum rail systems, and easily clamp to braces via their anchors for quick installation.
Personal Fall Arrest (PFA) Systems
Last but certainly not least, there are PFA systems. These systems include many components all with their own unique regulatory requirements, such as connectors, lanyards, lifelines, harnesses, and anchorages. While we will not go into the specifics of each of those regulatory requirements in this article, it’s worth mentioning that, if a PFA system is intended to be used for fall protection, it must do the following:
- Limit maximum arresting force on an employee to 1,800 pounds when used in conjunction with a body harness
- Be rigged in such a way that the employee cannot fall free more than 6 feet or contact a lower level
- Bring a worker to a complete stop and limit deceleration distance when the employee travels to 3 1/2 feet
- Have sufficient strength to withstand twice the potential impact energy of an employee free-falling a distance of 6 feet or the free-fall distance permitted by the system
For more information regarding any of the equipment mentioned in this article or how you can create a fall protection plan for your jobsite, don’t hesitate to get in touch with a representative from Cotney Construction Law.
Disclaimer: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.