OSHA has established three zones if you will on a roof surface. They can be easily seen in the next page illustration. The easiest to define is the “red” zone and this is 0-6ft from a fall hazard. When workers are in this area, they must be protected by one of three systems laid out by OSHA and they are Guardrail, Safety Net or Fall Protection System. The other areas defined by colors yellow and green in the diagram have additional criteria that might be able to be met if length of time or other restraints such as designated areas can be met. In the window cleaning and power washing industries we see all too often workers in the red zone not being tied off. For example, roof washing, gutter cleaning and possibly window cleaning all could fall into this zone very easily so understanding these zones is crucial.
Let’s now dispel rumors that are often quoted.
1. The Rule only applies to certain slopes.
False
The guidelines laid out in OSHA 1910.28 are referencing low slope roofs which OSHA defines as 4/12 or less so pitch isn’t the defining factor.
2. If it takes me only a few minutes it’s ok not to wear fall protection.
False
As you can see in the OSHA guidelines before there is no mention to amount of time spent in the zone. A fall can happen very quickly.
3. I am an owner operator, so I don’t have to follow the guidelines as laid out by OSHA.
True
However, gravity doesn’t discriminate by title. An owner/operator should still care about falling and the potential impact that could cause his/her family, business etc.
In conclusion, please reference the below OSHA guidelines and roof diagram to make sure you understand walking a roof surface and as always,
Be Safe Out There!
1910.28(b)(13)
Work on low-slope roofs.
1910.28(b)(13)(i)
When work is performed less than 6 feet (1.6 m) 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.
1910.28(b)(13)(ii)
When work is performed at least 6 feet (1.6 m) but less than 15 feet (4.6 m) 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.
1910.28(b)(13)(iii)
When work is performed 15 feet (4.6 m) or more from the roof edge, the employer must:
1910.28(b)(13)(iii)(A)
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
1910.28(b)(13)(iii)(B)
Implement and enforce a work rule prohibiting employees from going within 15 feet (4.6 m) of the roof edge without using fall protection in accordance with paragraphs (b)(13)(i) and (ii) of this section.
-By Michael Draper