Up on the Roof

Did you know that falls from heights are one of the most common sources of injury and death? This goes for the workplace as well as the home environment. As an employer, you are required under OSHA’s general duty clause to provide and maintain a safe work environment. For example, when employees are on a flat roof of a finished structure, they must stay at least 6 feet from the roof edge unless there is a parapet that meets OSHA standards for height. If there is no conforming physical barrier at the roof edge, then employees must say at least six feet from the edge of the roof. Sometimes companies overlook employee safety outside of the manufacturing environment. So you should also consider the work environment for your maintenance personnel.

In the work environment, OSHA requires that fall protection is provided at elevations of four feet and higher in general industry, five foot and higher in the maritime industry and six feet and higher in the construction industry.

For more information see: https://www.osha.gov/SLTC/fallprotection/standards.html.

Although the need for fall protection may be apparent, you still should assess task hazards with a job hazard analysis (JHA) or similar assessment tool to better determine what type of fall protection is needed to protect workers.

Using the OSHA hierarchy, first remove the hazard if possible and/or re-design the task(s) so that employees are not exposed to the hazard. If this can’t be done or is not fully effective, then install engineering controls such as guard rails and other features to physically prevent a fall from one level to a lower level. When all else fails, then you may employ PPE (personal protective equipment) to protect the worker. Use a JHA to document your assessment determination; it becomes your reference point and proof of concept.

When managing a work environment with fall hazards, as applicable, be sure to incorporate these aspects:

  1. provide and maintain fall protection equipment;
  2. engineer, install and/or maintain fall protection devices such as railings;
  3. train employee on the use and care of fall protection PPE;
  4. use approved designated and/or engineered fall protection attachment points;
  5. inspect fall protection PPE;
  6. remove damaged fall protection equipment and/or PPE from service;
  7. properly manage and document fall protection equipment put into service;
  8. properly wear and adjust fall protection PPE;
  9. maintain 100 percent tie-off when using fall protection PPE;
  10. wear fall protection PPE while in boom lift baskets and other aerial work platforms.

This list is not intended to be all inclusive. As an employer, the onus is on you to provide a safe and health workplace for your employees.

From our experience, while violations occur across industries, residential and commercial construction are typically problematic.

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