This article reprinted from Western Roofing magazine May/June 2007.

New Regulations

Regulations for New, "Production Type" Residential Roofing Work in Effect

by Bill Callahan, executive director, ARC of the Bay Area Counties

In the culmination of a regulatory process lasting nearly three years, the Cal-OSHA Standards Board at its January 18 meeting approved regulations governing roof hazards on new, "production type” residential construction. The new regulations subsequently passed muster with the Office of Administrative Law and are in effect as of April 1.

Although limited in scope to a fairly narrow sector of the roofing industry, the effects of new Section 1731 of the Construction Safety Orders are nonetheless dramatic. Most significantly, it lowers the trigger height for the provision of fall protection from 20’ to 15’ for moderately sloped roofs (3:12 through 7:12) and from 20’ to zero feet for severely sloped roofs (steeper than 7:12). The new regulations also decrease the number of fall protection options available to roofing contractors and impose new training requirements designed to ensure that employees are more aware of the fall hazards associated with roofing work. Together, these requirements should increase worker safety in the high-hazard, residential tract sector, while providing useful "cover" for the rest of the industry should federal OSHA ever insist that California conform to national standards and adopt a 6’ trigger height for all roofing operations.

Scope of 8 CCR 1731

The vast majority of roofing work is not subject to new Section 1731. Only roofing projects that meet all four (4) of the following conditions are affected:

1. New - the regulations only apply to roofing operations on new construction. Reroofing operations, roof replacements, and roofing work on additions to existing buildings are all specifically excluded from the scope of the new regulations;

2. Residential - the regulations only apply to roofing operations on residential structures (homes, condominiums, apartment buildings, etc.). The regulations do not apply to commercial, industrial, institutional, or any other type of non-residential roofing work;

3. Production-Type - the regulations only apply to tract-type housing developments, condominium complexes, and apartment buildings. Custom built homes, defined as single detached housing units built under a single contract, are not subject to the new regulations; and

4. Slope of 3:12 or greater. Finally, only those new, production-type, residential roofs that have a slope of 3:12 or greater are subject to new Section 1731, if the roof new regulations do not apply.

Fall Protection Options

Both the applicable trigger height for the provision of fall protection and the fall protection options available to contractors performing work subject to new Section 1731 vary depending upon the slope of the roof.

For moderately sloped roofs (those with slopes of 3:12 through 7:12), the applicable trigger height is 15’ from the eave to the grade or level below. Fall protection can be provided for employees working on such roofs by the use of one or any combination of the following methods: a) personal fall protection, per Section 1670; b) catch platforms, per Section 1724(c); c) scaffold platforms, per Section 1724(d); d) eave barriers per Section 1724(e); e) standard railings and toeboards, per Article 16; and f) roof jack systems, per Section 1724(a).

These fall protection options should have a familiar ring to them. They are exactly the same as those set forth in existing Section 1730(f), which governs the application of "multiple-unit roof coverings" to roofs with slopes greater than 5:12. New Section 1731(c)(1) simply lowers the applicable fall protection trigger height to 15’ and constricts the range of roof slopes within which these fall protection methods may be used when performing roofing work on new, production-type residential projects.

The changes wrought by the new regulations are more dramatic with respect to severely sloped roofing work. In the first instance, contractors performing subject work on roofs with slopes steeper than 7:12 have fewer fall protection options available to them. Eave barriers and roof jack systems (items (d) and (f), above) cannot be used on such roofs. Contractors must select from among only four options: personal fall protection, catch platforms, scaffold platforms, and standard railings and toeboards. More significantly, one or any combination of these fall protection methods must be provided regardless of height. In effect, this requirement sets the fall protection trigger height for severely sloped roofing work on structures subject to new Section 1731 at zero feet. •••