Protecting Roofers with Fall Protection
Taking the Right Steps to Ensure Roof Safety
by Philip Jacklin, Continuing Education Program Manager, Diversified Fall Protection
Let’s get straight to the point: falls have been and continue to be one of the leading causes of workplace injuries and fatalities. Perhaps roofers, who are almost constantly exposed to significant falls from heights while working, would not be surprised to learn that the United States Bureau of Labor Statistics listed roofing as the third-deadliest occupation in the 2022 Census of Fatal Occupational Injuries Summary. Their summary reported 124 deaths among roofing contractors that year, with 80% of the fatalities being caused by slips, trips, or falls.
The Occupational Safety and Health Association (OSHA) requires rooftop fall protection in many circumstances. However, providing rooftop fall protection is not always straightforward, and various complications or challenges can arise, making the installation of fall protection equipment a more difficult task. Despite these challenges, the safety and well-being of all workers is worth overcoming any challenge in providing essential safety equipment. This article outlines various fall protection requirements in the roofing industry and provides possible solutions companies can utilize to protect their workers.
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 for roofing contractors. Ultimately, it is the employer’s responsibility to verify the regulatory jurisdiction to which they are subject.
Unless stated otherwise, most OSHA fall protection requirements pertain to surfaces and rooftop areas with a pitch lower than 4:12. 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 one of the most common and effective means of fall protection roofers can use. It requires no additional training, inspections, certifications, or maintenance, as opposed to other fall protection systems. Additionally, a physical barricade, such as guardrail, can physically prevent a worker from falling off their work area.
Many companies, especially during construction, utilize non-penetrating guardrails to protect their workers. These guardrail panels still meet OSHA specifications without the need for penetrating the roof’s substrate. However, they may prove difficult to use in certain environments, like standing-seam rooftops. In that case, permanently-installed guardrail with specific attachments may be necessary, or perhaps another fall protection method entirely should be considered.
However, guardrail is significantly more effective than other fall protection solutions because it prevents falls from occurring. Preventing a fall is the only sure way to prevent injury. Other fall protection equipment can only, at best, lessen the severity of the fall victim’s injuries.
Fall restraint, also known as active travel restraint, is the next-best solution if installing guardrails is not possible or feasible. In roofing, this is a widely used practice utilizing rope-based vertical lifeline kits. Workers donning full-body harnesses can attach their kit to a single-point anchorage for one user or a horizontal lifeline system for many users. The worker will adjust their rope depending on the distance they must work away from their anchor point. As long as the worker only dispenses as much rope as necessary to restrain their travel and stay within the rooftop, they can be prevented from being able to fall off the roof.
These systems are widely used and work excellently in practice; however, they are highly vulnerable to user misuse or neglect. Employers must ensure that employees are well-trained on these systems and should conduct regular audits of their crews to verify compliance.
In areas where fall restraint systems can’t successfully reach or on steep-sloped roofs, an active fall arrest system can be used to protect workers. When workers use fall arrest equipment, their fall cannot be prevented, but the equipment can help lessen the severity of the injury incurred from a fall.
These systems will also require a full-body harness and anchorage, in addition to a shock-absorbing connection device. Workers must ensure their working height is located above the minimum required fall clearance distance for their connection device to ensure its ultimate effectiveness. That distance can be found in the device’s instruction manual. If workers are not positioned high enough off the ground for their connection device, their fall may not be fully arrested, and they could come into contact with the ground during fall arrest. If that happens, the victim could be subject to increased fall forces and potentially more severe injuries.
Furthermore, employers must ensure to provide Class Two Self-Retracting Lifelines (SRLs) for workers needing fall arrest when their anchorages are located at the user’s foot-level or anywhere beneath their harness’s Dorsal D-ring. This is in reference to a recent change to the ANSI Z359.14 Fall Protection standard took effect in August 2023. When SRLs are used with overhead anchorages, very little free fall occurs, and thus, minimal fall forces are generated. However, when falls occur from foot-level anchor points, users will experience free fall until they pass beneath the location of their anchor, and be generating fall forces the entire time. Class One SRLs are not rated to withstand those additional forces and could potentially fail to properly protect the worker. Class Two SRLs can give employers peace of mind that their workers will be protected no matter where their anchorage is located on any given job site or rooftop.
The importance of fall protection cannot be understated in the roofing industry. Falls can happen in a split second, and no reaction can make up for a lack of preparation. Companies like Diversified Fall Protection partner with organizations to make sure their fall protection programs are comprehensive, effective, and practical. If we can provide workers with the means to be protected from falls while working, we can benefit from avoiding preventable deaths.
