Roof Rules Depend on Slope, Distance, and Frequency

Falls from heights and on the same level when on working surfaces continue to be among the leading causes of serious work-related injuries and deaths. Performing elevated work is no less hazardous when done infrequently and temporarily, such as equipment service on low-slope or flat rooftops.

Because of this, in November 2018, OSHA issued a final rule updating the previously outdated Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) general industry standard to better protect workers from slip, trip, and fall hazards.

For specifics, reference OSHA’s 29CFR Subpart D and Subpart I, in particular 1910.28 (Duty to have fall protection and falling object protection) and 1910.140 (Personal fall protection systems).

At all distances from the roof edge, employees must be protected from falling by a guardrail, safety net, or fall arrest/restraint system. However, on a low sloped roof there is some flexibility when the work is temporary and infrequent.

If the work performed is at least 6 feet but less than 15 feet from the roof edge the employer may use a designated area.  If the work performed is 15 feet or more from the roof edge, conventional fall protection system may not be required.  In all cases, OSHA requires enforcing a work rule prohibiting employees from going outside of the designated area without using fall protection.

The recent change raises the question: What is OSHA’s definition of “temporary and infrequent”? Unfortunately, the phrase “temporary and infrequent,” is not defined within the OSHA regulation. To answer this, employers must reference OSHA’s preamble to the Walking Working Surface regulation.

OSHA defines “temporary and infrequent” as:

• Temporary: Simple, short-term tasks that require a maximum duration of two hours to complete. The examples provided by OSHA include changing a filter in a rooftop HVAC system, replacing a part on a satellite dish, caulking or resealing the flashing around a skylight, or sweeping a chimney.
• Infrequent: A task or job is performed only on occasion, once per month or less. Infrequent tasks include annual maintenance or servicing of equipment, monthly or quarterly replacement of batteries or HVAC filters, and responding to an equipment outage or breakdown.

The newly updated standard also references the term “designated area.” What are the requirements for a designated area?

As noted in the preamble, a designated area means “a distinct portion of a walking-working surface delineated by a warning line in which work may be performed without additional fall protection.” OSHA does not permit the use of painted lines to mark out a designated area. There must be a physical barrier consisting of a rope, wire, tape, or chain.

Further specific requirements for “designated area” delineation are found under 1910.29. Ensure that each warning line:

• Has a minimum breaking strength of 200 pounds.
• Is installed so its lowest point, including sag, is not less than 34 inches (86 cm) and not more than 39 inches (99 cm) above the walking-working surface.
• Is supported to ensure that, if the warning line is pulled, it will not result in slack being taken up in adjacent sections causing the line to fall below the specified height requirement of 34”-39”.
• Is clearly visible from a distance of 25 feet away, and anywhere within the designated area;
• Is erected not less than 6 feet (1.8 m) from the roof edge for work that is both temporary and infrequent, or not less than 15 feet (4.6 m) for other work.

Lastly, if the work is taking place 15 feet or more from the edge of the roof, the employer is not required to provide fall protection or use a designated area, provided the work is both infrequent and temporary and the employer implements and enforces a work rule prohibiting employees from going within 15 feet of the roof edge without using fall protection. This policy should note not to deviate from walking paths and include a sign-off sheet mandating protocols be followed on the roof.

To summarize, on a low slope or flat roof:

Use of a designated area in lieu of conventional fall arrest systems can be used if the work is:

• at least 6 feet from the edge and the job is defined as both temporary and infrequent;
• or at least 15 feet from the edge, regardless of job duration.

A designated area is not an option (and conventional fall protection is required) if the work is:

• within 6 feet of the edge;
• or within 15 feet from the edge and does not qualify as temporary and infrequent.

For any work performed on a rooftop with a pitch greater than 4:12, regardless of distance from leading edge, conventional fall protection such as guard rails, safety net, travel restraint, or personal fall arrest is required.

For further information and resources on this topic, visit MEMIC’s Safety Director, which includes a tool to conduct a self-assessment of your fall protection program.

Additional Resources:

• MEMIC blog: The Flat Roof Dilemma - When is Fall Protection Required in General Industry?
• MEMIC Podcast: Protection at the Edge - How Your Fall Protection Equipment Can Let You Down
• MEMIC Podcast: The Flat Roof Dilemma - When is Fall Protection Required with David Kozlowsky
• MEMIC Podcast: Implementing Proper Fall Protection with David Kozlowsky

By Jayson Hebert

Courtesy of MEMIC

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