About Jay Acker

Jay Acker is a technical writer for Tempe, Ariz.-based Safety Services Co., a supplier of occupational health and safety training and compliance materials.

How Is Your Fall-protection Plan?

Citing “record numbers” of unsafe roofing complaints in the Denver area during the first half of 2014, OSHA began its own outreach efforts and partnered with organizations, like the Colorado Roofing Association (CRA) and the Better Business Bureau (BBB), to make fall protection a priority among roofers and encourage consumers to hire roofing companies who do.

“In the past six months, we have received 63 complaints related to unsafe work practices, and this is the beginning of roofing season,” said David Nelson, OSHA’s area director in Englewood, Colo.

This emphasis contains two messages: the first to get consumers to hire contractors with a safety plan and good record; the second to prompt roofers to develop and follow safe work practices.


Among its efforts, OSHA emphasized that home and business owners should use the OSHA website, CRA and BBB to hire reputable roofing companies with a safe work record without safety violations. OSHA advises consumers ask probing questions of roofing contractor’s safety plans, such as:

    ▪▪ Are the installers your employees or subcontractors?
    ▪▪ Are they insured?
    ▪▪ What is their past work history?
    ▪▪ How will the project be managed?
    ▪▪ What kind of fall protection will be used?


For roofing contracting companies, OSHA hosted a 2014 National Safety Stand-Down week on June 2-6 that encouraged employers to stop work for one week to discuss fall hazards and safety measures.

At the end of June, the same OSHA Region 8 (Colorado, Montana, North Dakota and South Dakota) announced it was going to spend extra energy enforcing safety in roofing following increased construction after a hailstorm.

“Falls from roofs, ladders and scaffolds can be prevented by planning ahead, providing the right equipment for the job and by training everyone working on a project to use the equipment safely,” said Jeff Funke, OSHA’s area director in Billings, Mont.

These efforts demonstrate that roofing companies need to be prepared and committed to an effective fall-protection safety plan and be able to answer questions about it to prevent injuries and protect the company if an accident happens, as well as help win jobs if customers ask about the safety plan.


Considering the reasons for adhering to a comprehensive plan, take a moment and review your fall-protection procedures. This should be done annually, anyway.

Ideally, all potential hazards that could be encountered are eliminated or addressed through proper protection, work practices and training. Often, expertise, past experience or industry standards will point out these potential work hazards that need to be rectified.

According to information provided by OSHA’s outreach, a comprehensive fall-protection plan should include at least preventing falls from roofs, ladders and scaffolding. OSHA stresses the need to plan for safety, provide the correct equipment and ensure everyone is trained in safe work practices. Consider the following:

Employees need to know when to wear a harness and how to ensure it fits. The proper guardrails and lifelines need to be implemented and used. Employees need to inspect all fall-protection equipment before using it and be able to determine when it is no longer safe. Holes, open stairwells, openings and skylights must be securely covered or guarded.

Employees must know how to select the correct ladder and the proper way to safely use all ladders. Regardless of the type of ladder, users must maintain three points of contact; always face the ladder; and, without overreaching, secure the ladder on level footing; as well as never stand on the top step.

Extension ladders are not self-supporting and, therefore, need a stable structure and foundation to withstand the load. In addition, the area around the bottom and top of the ladder must have sufficient unobstructed space.

Plan to have an extension ladder that can hold at least four times the weight you intend to put on it. That includes any people and equipment and materials.

Also have a “competent person” visually inspect the ladder and secure the top of the ladder to a solid support. (A competent person is a technical term for someone who has the training and experience to know how to act safely and the authority to make a decision.)

Other safe work practices that should be followed include:

    ▪▪ Check the location of power lines before placing the ladder.
    ▪▪ Stay near the middle of the rungs while going up or down.
    ▪▪ Use barriers while on the ladder to keep traffic away, especially near doors and entryways.
    ▪▪ Only use the ladder for the purpose it was designed.

Basic scaffold safety incorporates using fully planked scaffolds and ensuring they are sturdy, plumb and level with all guardrails completed and with stable footing. The scaffold must be used properly and accessed through a properly provided route; users should not climb on cross braces or stand on guardrails. Ladders also can’t be used on top of a scaffold.

A competent person—someone with the experience to recognize hazards and the authority to fix them—must inspect the scaffold before use.


OSHA’s outreach is another example of it using incidents and complaints to focus attention on an industry. But it’s not just roofing contractors who are receiving increased attention.

In February, OSHA contacted communication-tower employers to remind them of their responsibility to train and monitor employee fall protection following 13 deaths in 2013 and four in the first weeks of 2014—a total higher than in the previous two years combined.

Ultimately, OSHA has reason to focus on particular industries, so it’s imperative you ensure your fall-protection program is effective.

OSHA’s Fall Protection Clarifications for Roofers

OSHA’s fall-protection regulations are easy to find (see OSHA 29 CFR, Subpart M, 1926.500 – 1926.503 and four appendixes). Understanding them is a bit more difficult because they apply to a variety of occupations, including roofing.

The following clarifications are OSHA’s responses to questions regarding fall-protection requirements and work practices affect roofers:


The “Holes” section of the regulation requires the use of fall protection— personal fall-arrest systems (PFAS), guardrails, safety nets, covers, etc.—when there is a hole in a work/walking surface. Because a roof is a work/walking surface, employees must be protected from falling through. OSHA concluded that immediately securing a cover over a cut hole is sufficient because the cover eliminates the fall hazard requiring fall protection. The rest of the environment may still require fall protection.


A supplier who delivers roofing material onto a roof must use all available fall protection, meaning a sufficient ladder or other means with a sturdy handhold. A supplier also must wear personal fall-protection equipment and connect to existing anchorage points when receiving and delivering materials on a roof.

If anchorage points do not exist for workers at the site, suppliers are not required to install anchorage points because they spend so little time at the job site. Anchorage points are the primary contractor’s responsibility, and it’s the supplier’s responsibility to use available fall protection.


A controlled access zone (CAZ) is a designated work area marked by a warning line that only authorized employees can cross to work next to an unprotected edge. This less-safe approach is explicitly reserved for leading-edge work (the changing unprotected side of a roof or floor as it is installed) and overhand brickwork.

Except for steep roofs (slopes greater than 4-inches vertical to 12-inches horizontal) and non-residential roofing, CAZs are an option if you can prove traditional fall protection is not possible or too dangerous. Just be prepared to justify in writing why other fall protection isn’t effective; identify all authorized employees; and investigate all accidents and near accidents.

Some examples where traditional fall protection fails:

    ▪▪ Safe anchors cannot be provided.
    ▪▪ Lifelines may entangle or mire in grout.
    ▪▪ Fall protection prevents completion of the work.
    ▪▪ Work-area configuration causes ineffective fall-arrest systems.

At the very least, the CAZ must include a safety monitoring system.


A safety monitor is a competent person responsible for recognizing and warning employees they are in danger of falling. The monitor counts as part of the fall-protection solution on low-slope roofs.

The following are fall-protection options on low-slope roofs:

    ▪▪ Guardrails
    ▪▪ Safety nets
    ▪▪ PFAS
    ▪▪ Warning lines and guardrails
    ▪▪ Warning lines and safety nets
    ▪▪ Warning lines and PFAS
    ▪▪ Warning lines and safety monitors
    ▪▪ Safety monitors on roofs 50-feet wide or less

The safety monitor must:

    ▪▪ Be competent to recognize fall hazards.
    ▪▪ Warn employees when it appears they are unaware of a fall hazard or are acting unsafely.
    ▪▪ Be on the same work/walking surface as monitored employees and be able to see them.
    ▪▪ Be close enough to talk to the employees.
    ▪▪ Not have any other responsibilities.
    ▪▪ Ensure employees follow warnings and directions.

Also, mechanical equipment can’t be in safety monitoring areas. Because these feasibility exceptions are only listed in specific categories (low-slope roof work, leading-edge work, precast concrete erection and residential construction), if a worker doesn’t fit those categories, such as HVAC installation, the worker must follow conventional fall protection. Alternative plans are generally for situations in which there isn’t a completed structure to attach anchor points; once anchor points are available, OSHA favors regular fall protection.


OSHA’s stance on fall protection is that there is no safe working distance away from an unprotected edge. But in an interpretation of workers on a low-slope roof, having just a warning line at least 15 feet from the edge of a roof for non-roofers (HVAC installers) would be considered a “de minimis” violation if non-roofers are prohibited from crossing the warning line. A de minimis violation violates regulations without making the workplace less safe and doesn’t result in a citation.


OSHA assumes traditional fall protection is safer than creating an alternative plan and has described some industry approaches to assembling and installing roofs without foregoing fall-protection precautions just because an anchor isn’t convenient:

    ▪▪ Assemble the roof on the ground and use a crane to place it.
    ▪▪ Use permanent and reusable roof anchors and reusable truss braces while working from ladders or platforms at both ends to brace the trusses without needing to be on them.
    ▪▪ Once trusses are braced, begin initial sheathing at the eaves with workers on platforms inside the structure, removing braces one at a time. Sheath the last course while tied off to existing wood anchors.

When OSHA regulations meet the real world, they can leave you wondering how they should be interpreted, and roofing is no exception. Hopefully this summary of how OSHA has interpreted fall protection for roofing situations clarifies some of the questions.