Working on a roof can be a hazardous job, and it is essential to comprehend the Occupational Safety and Health Administration (OSHA) regulations for roof safety. In the construction industry, employers must provide fall protection to roofers whenever they work at heights of six feet or more above a lower level. For the industry in general, employers must guarantee that workers are safeguarded at heights of four feet or more. To meet OSHA roof fall protection requirements, employers must provide railings with skirting boards, safety net systems, or personal fall arrest systems.
Ideally, all roof systems that require maintenance should be situated within the High Danger Zone (15 feet or more from the edge) in the center of the building. This area provides a first line of defense with a 15-foot warning line. In the Midwest, this line should be 39 to 42 inches high and usually yellow so that those on the roof are aware that they should not cross that line without the restrictions required by OSHA. Additionally, no roofer should work without a helmet.
OSHA also stipulates that materials must be stored in a manner convenient for workers involved in roof work, such as those doing carpentry work. While roofing carpentry materials are usually close to the roof, other materials should be kept no more than six feet from the edge of the roof. Materials must be perfectly positioned so that they do not pose any risk to employees. Two OSHA standards can apply: 29 CFR 1910, which governs “general industry safety standards,” and 29 CFR 1926, which specifically governs construction sites.
Determining which one you must comply with can be a challenge. If you don't know the OSHA regulations for fall protection, consult an OSHA safety officer about specific requirements for working on rooftops. The responsibility for maintaining the safety standards required by OSHA will always rest with the host employer when several contractors are working on a site. If you use a crane or elevator, you must apply the 1926 roof fall protection regulations, even if the work is relatively routine.
Replacing a rooftop convection system with an air-conditioning system throughout the building involving the use of a crane should be considered construction and require the use of railings as per the 1926 standard, at a minimum. Section 1926,501 further requires that safety net systems, guardrail systems, or personal fall arrest systems (PFAS) be used to ensure that employees do not fall when working on a 6-foot-high ceiling or on a lower level. There are OSHA standards that define the safety distances from the edge of a roof and the degree of protection required. OSHA provides many resources on this topic, including fall prevention for construction workers, gastrointestinal surfaces for walking and working, the OSHA fact sheet, and OSHA publications dedicated to all aspects of fall prevention. Kozlowski's best advice is to start thinking of the roof “just like another floor in the building” and to always remember that it is your responsibility to ensure that every roofing professional goes home safely at the end of the day.