OSHA has released extensive revisions to Subpart D of their general industry standards, which are requirements which apply in nearly all workplaces, other than construction settings. In other words, this rule applies to nearly all employers, other than construction!
Subpart D deals with “walking and working surfaces” and, as the name implies, contains rules pertaining to ladders, stairs, floors, scaffolds, low slope roofs, and the like.
The revisions are lengthy and detailed but buried in them is an interesting requirement which will require some general industry employers, in some cases, to develop formal, written safety rules for employees who access low slope roofs, and to adequately communicate those rules to appropriate employees.
The rule applies to low slope roofs, which OSHA defines as “a roof that has a slope less than or equal to a ratio of 4 in 12 (vertical to horizontal).”
In an effort to prevent employees from falling from these rooftops, OSHA promulgated a set of requirements for fall protection, which vary depending on how far the employee is from the edge of the roof. For instance:
- When work is performed less than 6 feet from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system.
- When work is performed at least 6 feet but less than 15 feet from the roof edge, the employer must ensure each employee is protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. The employer may use a designated area when performing work that is both infrequent and temporary.
However, when employees are 15 feet or more from the roof edge, the employer must “protect each employee from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system or a designated area. The employer is not required to provide any fall protection, provided the work is both infrequent and temporary; and implement and enforce a work rule prohibiting employees from going within 15 feet of the roof edge without using fall protection in accordance with the other requirements above.
So in plain English;
- If your employees ever access any low slope roof, for any reason (i.e. servicing or changing filters in air handling units, electrical repair or maintenance, raising or lowering flags, installing/removing seasonal lighting or displays, etc.), you will be required to take steps to protect those employees from falling.
- The difficulty and cost involved with protecting them will increase if their work takes them closer to the edge, so it will behoove an employer to find ways to prevent the need to do this.
- However, even when employees stay far back from the edge, the employer will still be required to require fall protection measures, unless the work is infrequent, temporary, and a written work rule is implemented and communicated, prohibiting employees from coming within 15 feet of the roof edge without fall protection.
If you would like assistance with this topic, or with developing your roof access safety rules, please call or email Paul at (612)597-6463 or firstname.lastname@example.org.