22 Dec Residential Roofing — “To Be Or Not To Be” – Tied Off?

Residential Roofing — “To Be Or Not To Be” – Tied Off?

OSHA’s “Subpart M” intended to standardize fall protection for the construction industry, but did not clearly define how those standards would apply to residential construction. At the request of industry associations, OSHA reconsidered the code and published an interim policy in December of 1995 which is considered to comply with Subpart M during residential roofing work where (1) the roof slope is 8-in-12 or less and (2) fall potential from lower eaves is 25 feet or less. Check with applicable state programs for inclusion of this optional federal change.

If conventional fall protection systems are not used, OSHA requires the following:

• All workers who are allowed on the roof must be proficient in the alternate methods of fall protection. Affected employees must also be trained in the specific hazards associated with work on roofs which have rake edges.
• Roof surfaces must be inspected for slipping hazards–either eliminating them or taking measures to ensure that employees avoid them.
• Workers must wear appropriate footwear to reduce slipping potential.
• Operations must be suspended when weather conditions such as high wind, rain, snow or sleet create a hazardous condition and must remain suspended until the condition has passed.
• Damaged portions of the roof deck must be repaired as soon as practicable. Any holes (including skylight openings) must be protected either by covers or by installing guardrails.
• Employees must be protected with a safety monitoring system or by roofing slide guards.
• Workers must not ascend or descend the roof slope within 6 feet of the rake edge, except where such a limit on movement would prevent the performance of work.
• Supplies and materials must not be stored within 6 feet of the rake edge, or three feet where tile and metal roof systems are being installed.
• The area below eaves and rakes must be kept clear of materials and other objects which could pose impalement hazards, or they must be guarded properly.

Employers who use roofing slide guards as fall protection must take additional precautions:

• On slopes of 6-in-12 or less, three rows of roofing material must be placed prior to installing slide guards. Guards must be capable of holding a worker’s weight should that person slip.
• On roofs with slopes greater than 6-in-12, up to and including 8-in-12, eaves slide guards must be installed for the entire length of the eaves. Additional guards must be installed below the work area at intervals not to exceed 8 feet. While standing on the plank below, the employee must secure roof jacks with nails and add planks, then climb up to the plank and continue to install the roof. Once the roof is installed, the employee will climb down to a lower plank and remove above planking and roof jacks until all jacks and planking have been removed.
• When a conventional method of fall protection must be provided:
• On roofs of 8-in-12 or greater, and on roofs with slopes greater than 4-in-12 where the fall potential measured from eaves is greater than 25 feet.
• Conventional methods include safety nets, guardrails or a personal fall arrest system.