Staying Secure
Providing Fall Protection for Workers on Steep Roofs
by Philip Jacklin, Diversified Fall Protection
Falls are one of the leading causes of injury and fatality in the workplace, and workers in the roofing industry are no exception. Some trades offer the convenience of only having a portion of their tasks take place at heights, but roofers are almost exclusively required to perform elevated work daily. Tragically, the United States Bureau of Labor Statistics reported year over year increases in roofer fatalities from 2021-2023: with 115, 124, and 134 deaths, respectively. Approximately 80% of those fatalities were attributed to falls from heights.
Flat or low-slope roofs pose significant risks for workers who must work near rooftop edges, but steep-sloped roofs offer more challenges with protecting workers from falling. However, almost all falls are preventable with sufficient planning and comprehensive training provided to workers. This article outlines some of the challenges associated with steep-sloped roof work and how companies can protect their most valuable asset: their workers.
Adhering to Occupational Safety and Health Administration (OSHA) minimum requirements should not be the ultimate goal for any organization, but it is a logical starting point for providing fall protection. Federal OSHA standards require employers to provide fall protection when general industry workers are exposed to falls of four feet or greater and when construction workers are exposed to falls of six feet or greater. Most roofing contractors are subject to general industry standards unless the roof is being newly constructed. Additionally, many states have their own state-run OSHA programs that may have different fall protection requirements. Companies should refer to their local OSHA offices to verify their regulatory jurisdiction and create policies based on their requirements.
OSHA defines a roof with a pitch over 4:12 to be considered a steep roof. On steep roofs, only guardrail, safety netting, and personal fall arrest systems are allowed for fall protection. On lower-slope roofs, fall restraint systems are adequate; however, due to the greater risk of slips, trips, and falls on steeper roofs, their use is not permitted.
Guardrail is considered one of the most effective forms of fall protection as it can prevent a worker from falling off the edge of the rooftop, thus significantly reducing the chance of severe injury. However, guardrail must comply with OSHA requirements to be compliant and as effective as possible.
The top rail of the guardrail must be a minimum of 42 inches high and be capable of withstanding 200 pounds of force in a downward or outward direction. The midrail should be evenly spaced between the top rail and toeboard and must withstand 150 pounds of force in a downward or outward direction. Toeboards must be at least of 3-1/2 inches tall, with no more than a 1/4 inch gap at the bottom and capable of withstanding 50 pounds of force. The full specifications for OSHA-compliant guardrail can be found in the General Industry OSHA 1910.29 code.
If guardrail is not feasible to install or its installation would be too dangerous for workers, then a personal fall arrest system should be utilized to protect workers. Fall arrest systems are effective at mitigating severe injury after a fall occurs, but they cannot prevent a fall from occurring. When deciding what type of fall arrest system to implement, be aware that there are two primary types of systems: single-point and linear.
Single-point anchorage systems allow workers to connect their lanyard or self-retracting lifeline (SRL) directly to their own dedicated anchor point. There are many permanent and temporary anchorage options available for purchase that are compatible with almost all roofing types, including concrete, steel, and wood. Some require no permanent fasteners at all. However, single-point anchors can only accommodate one worker at a time, and workers must be sure not to work more than 15 degrees away from their anchor point. Workers that are too far away from their anchor point run the risk of experiencing swing fall, which increases their fall distance as well as their risk of severe injury. If workers must walk more than 15 degrees away from one anchor, multiple anchors should be installed so that workers can transition to another anchor point. In these scenarios, workers must be provided with twin-leg lanyards or SRLs so they can transition from one anchor to another while sustaining continuous fall protection.
On larger rooftops where workers must navigate large working areas, linear systems may be more ideal. Linear systems, such as horizontal lifelines, help workers to operate in larger work areas without needing to reconnect to new anchorages every few feet. Some horizontal lifeline systems can even accommodate up to four workers in fall arrest by using only two anchors on each end. Companies should always verify system capabilities and train workers not to misuse these systems. Misusing fall protection and neglecting the manufacturer’s instructions can not only lead to severe injury for the worker but also expose the employer to potential OSHA violations and citations.
According to a 2021 survey conducted by the Center for Construction Research and Training (CPWR), respondents identified insufficient planning as the leading cause of fatal falls. Simply put, these organizations did not take the time to plan for nor provide proper fall protection to workers, and workers died as a consequence. All falls are preventable with the proper equipment and training.
Before work on steep roofs begins, employers should do their best to coordinate with the general contractor, the building owner, or both, to verify what fall protection equipment is currently in place on the rooftop. If none exists, they should discuss what type of fall protection can be installed before work begins, so workers are exposed to minimal fall hazards and have the means to protect themselves and mitigate injury. All workers deserve the opportunity to make it home, and providing fall protection is one way to guarantee that they do.
OSHA requires all employers to train and designate all workers that will use fall protection equipment as Authorized Users before they can use the equipment. This training must be provided by the organization’s Competent Person or an ANSI-accredited third-party trainer, like Diversified Fall Protection. Retraining should occur when changes are made to the equipment, environment, or policies that will affect workers or when workers are observed to show a gap in understanding that leads them to work unsafely. Industry experts recommend fall protection training to be conducted annually at a minimum to maintain awareness of this hazard.
Furthermore, OSHA requires fall protection training to be provided in multiple languages if necessary to accommodate diverse workforces. In 2023, the CPWR published data that showed Hispanic workers were more likely to die from falls, with a fatality rate 50% higher than non-Hispanic workers. While Hispanic workers make up only 7.9% of the total workforce, a 2020 report from the United States Bureau of Labor Statistics reported that they accounted for approximately 26% of all slip, trip, and fall fatalities.
While providing fall protection to workers on steep roofs can be a daunting task for employers, workers deserve every effort to ensure their safety. Any life lost to a preventable fall should be considered a tragedy. Companies like Diversified Fall Protection can help organizations stay informed about updates to OSHA regulations, identify rooftop hazards, and provide training to employees. Together, we can make significant progress in providing fall protection to all workers and build a safer world for everyone.
