Walking Working Surfaces Standard Update: Roof Maintenance

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This year, OSHA made updates to its Walking Working Surfaces standard for general industry, in an effort to bring fall protection requirements more in-line with those for the construction industry. As a result, OSHA estimates the new rule will prevent 29 worker deaths and 5,842 lost-workday injuries each year. In addition, compliance will be easier and more affordable to maintain, since the requirements now overlap industries and many existing ANSI (American National Standards Institute) standards.

While the Walking Working Surfaces standard addresses many common scenarios for general industry, such as fixed ladders, rope descent systems and scaffolding, this blog focuses specifically on avoiding the unique hazards of rooftop environments.

Identifying the Danger Zones

One of the key updates to the regulation impacts maintenance work on low-slope – “4 in 12 pitch”– or flat roofs. The most common question asked when assessing the potential hazard is: “What is a safe distance to maintain when performing work on an unprotected roof edge?” The final rule answers that question and adds additional clarification by dividing low-slope roof work into three distinct categories.

1. Work Performed Less Than 6’ From the Roof’s Edge

This requirement is rather straightforward and does not allow for much flexibility. It also closely mirrors the construction standard. OSHA requires the use of conventional fall protection systems in this area (i.e., a guardrail system, safety net systems or personal fall protection system). Warning line systems are not allowed in this area under any circumstance.

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Depending on the type of maintenance a worker is doing, proper consideration should be given to plan the tasks and identify what safety measures make the most sense. Also consider the frequency that this work might typically take place over the course in a given year. Remember that OSHA allows workers to access an area without fall protection in order to install or set up a personal fall protective system or guardrail depending on which solution is chosen.

One of the easiest and safest techniques for working near a roof edge is to consider a fall restraint system, such as a rope grab device that prevents you from going beyond the roof edge. These units can usually be installed in minutes for basic maintenance tasks.

2. Work Performed Between 6’ and 15’ From the Roof's Edge

While employers are still permitted to use a conventional fall protection system, 6’ away from the roof’s edge is the closest you would be allowed to us a warning line system – commonly referred to as a “designated area”– but only when performing work that is both infrequent and temporary.

There are three things to consider when using working in this particular zone:

A. Rather than using any available rope, stick to the specified requirements regarding spacing of the flags, tensile strength of the warning line, etc. You must ensure the warning line meets the strength and sag requirements listed under 1910.29(d).

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B. You cannot simply place a warning line on the side of the roof where you are working only. You must encase the entire roof area, even though it can often become time consuming and expensive.

C. You have to make sure the work is both infrequent and temporary. Although this can be a bit of a judgment call, the OSHA preamble does help give us better clarification.

TEMPORARY

• The worker is able to perform the task in less time than it takes to install or set up conventional fall protection equipment.

• The task can be completed in one session, rather than repeatedly climbing or returning to the roof, or spread out over more than one shift.

• Simple tasks which do not require significant equipment, personnel or other resources.

• Generally, less than 1-2 hours to complete the task.

INFREQUENT

• Performed only on occasion, when needed or at sporadic or irregular intervals.

• Examples include annual maintenance or servicing of equipment (monthly or quarterly), replacement of batteries or HVAC filters, responding to - equipment outage or breakdown.

• Considered infrequent if performed once a month, once a year or as needed.

 

 

3. Work Performed Greater than 15’ From the Roof’s Edge

Employers can use conventional fall protection systems for a designated area. However, if the work is both infrequent and temporary, employers do not have to provide any fall protection – not even a warning line. They would then need to implement and enforce a work rule prohibiting employees from going within 15’ of the roof edge without a fall protection restraint, in accordance with final paragraphs (b) (13) (i) and (ii). If the work is either “frequent” or “more permanent” then a warning line should be used 15’ from the roof edge. OSHA believes this limited exception eases compliance for employers without compromising worker safety.

Other Roof Considerations

In addition, there are other potentially hazardous roof fixture to consider like roof hatches and skylights. Fixed ladders are commonly used to access a roof through a roof hatch in the ceiling of a building. OSHA requires hatch covers to open sufficiently when entering and exiting the roof (70 degrees from horizontal if counterbalanced) and that the cover is closed, or that a removable guardrail system is provided on the exposed sides.

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Under 1910.28 (duty to have fall protection and falling object protection), standards for skylights require that protection from a cover, guardrail systems, travel restraint systems or personal fall arrest systems is in place. Common approaches include placing a guardrail around the skylight or using an approved metal mesh screen.

General Industry vs. Construction: Knowing the Difference

While OSHA has mirrored many of the requirements from the construction industry’s Fall Protection standard, there are some distinct differences that need to be heeded when following the general industry requirements. Primarily, the construction standard allows employers to use warning line systems in combination with a safety monitoring system for roofing work activity while the general industry standard does not. Since we do not currently have compliance directives to help us better understand OSHA’s intent of this standard, the preamble is a great resource to help safety professionals best interpret the regulation.

Source: OSHA Federal Register/Vo. 81: pages 82612-82615

2017 Walking-Working Surface Standard: Identifying Solutions for the OSHA Updates