Konecranes Offers Training Courses to Reduce Crane Accidents

Konecranes Training Institute aims to reduce crane accidents through education.

Konecranes Training Institute aims to reduce crane accidents through education.

Konecranes is an overhead crane manufacturer with a complete range of lifting equipment and industrial crane service professionals. Konecranes Training Institute in New Berlin, Wis. is a key element in the portfolio of equipment and expertise with which Konecranes supports its customers.

“Many crane accidents are caused by poor or improper rigging practices,” says Jim Lang, general manager of the Konecranes Training Institute. “One of the key items we learned from our Crane Accident study covering 10 years’ worth of overhead crane accidents was that 59 percent of the time when a load dropped this was because of a rigging issue. This very common deficiency is what we address in our Rigging Fundamentals course.”

Details revealed by the study are available in a short video produced by Konecranes Training Institute. It can be estimated that up to 70 percent of the overhead crane accidents may have been prevented by proper training.

According to Lang, the Rigging Fundamentals course from the Konecranes Training Institute teaches workers how to safely rig loads for different lifting conditions. For example, a 5,000-pound load rigged for a low headroom lift close to the ceiling could potentially require chains rated at 25,000 pounds or greater rather than 5,000 pounds depending on the angle between the hook and the load. Acute angles may multiply lifting stresses by more than five times the actual weight of the load.

Nucor Steel Gallatin in Ghent, Ky. has hosted the Rigging Fundamentals and Signalling courses more than 20 times, covering more than 300 employees over in 2014. According to Nucor Steel Gallatin’s Electrical Engineer Joe Rachford, the course has been invaluable since OSHA regulations changed to differentiate between operational and construction lifts.

“We could be picking up a motor, and if it is an in-kind motor, that is a maintenance lift and qualifies as operational. However, if it is an upgraded energy-efficient motor, it becomes a construction lift as it is new equipment,” says Rachford. “To cover ourselves, we now train everyone to the more stringent standards for construction lifts.”

Rachford says that while Konecranes training overlaps much of what Nucor had already established with their normal maintenance procedures, the Konecranes course is more technical and contains much more detail.

“We received very positive critiques coming back from the individual associates who completed the classes. I looked at every one and for the most part, all were very complimentary,” says Rachford.

Nucor Steel‘s Gallatin campus is now working with Jim Lang to put four individuals through Konecranes “train the trainer” course to ensure that there is a trainer available on-site when needed. Instructors must complete training every two years to remain certified, and the training materials are licensed from Konecranes.

“Since all of our new hires must complete the course before they can perform construction lift work, this program gives us the ability to go to our training room and immediately provide the same one-on-one instruction that Konecranes conducts on site,” says Rachford. “It is a great time-saver for us.”

Konecranes Training Institute lists all available courses and its regional seminars on the Konecranes training website.

CISC Report: Proposed Silica Rule Will Cost 10 Times OSHA’s Estimates

A report released by the Construction Industry Safety Coalition (CISC) found that the Occupational Safety and Health Administration’s (OSHA) proposed silica standards for U.S. construction industry will cost the industry $5 billion per year—roughly $4.5 billion per year more than OSHA’s estimates. The coalition cautioned that the flawed cost estimates reflect deeper flaws in the rule and urged the federal agency to reconsider its approach.

OSHA’s proposed rule, intended to drastically reduce the permissible exposure limit (PEL) of crystalline silica for the construction industry, has been underestimated by the agency to cost the construction industry about $511 million a year. The estimates released by CISC estimate that the costs to the industry will actually be approximately 10 times the OSHA estimate—costing nearly $5 billion a year.

The cost and impact analysis from OSHA reflects a fundamental misunderstanding of the construction industry. The OSHA analysis included major errors and omissions that account for the large discrepancies with the CISC report. The CISC report estimates that about 80 percent of the cost ($3.9 billion per year) will be direct compliance expenditures by the industry such as additional equipment, labor and record-keeping costs. The remaining 20 percent of the cost ($1.05 billion per year) will come in the form of increased prices that the industry will have to pay for construction materials and building products such as concrete block, glass, roofing shingles and more. OSHA failed to take into account these additional costs to the construction industry that will result from the proposed standard, which will then be passed down to customers in the form of higher prices.

Not only will the proposed rule be more costly than originally estimated, but it would translate into significant job losses for the construction industry and the broader economy. The CISC estimates that the proposed regulation would reduce the number of jobs in the U.S. economy by more than 52,700 yearly. That figure includes construction industry jobs, jobs in related industries such as building material suppliers, equipment manufacturers and architects, as well as losses in non-construction sectors. Additionally, the losses are full time employee positions. Factoring in the many part-time or seasonal jobs, that number could increase to close to 80,000 positions lost.

“We are deeply concerned about the misguided assumptions and cost and impact errors that OSHA has relied upon in creating this proposed rule that will significantly affect our industry,” says NAHB chairman Tom Woods, a home builder from Blue Springs, Mo. “This report reveals the critical need for OSHA to withdraw its proposed rule until it can put forth a technologically and economically feasible rule that also works to improve industry workers health and safety.”

“This report clearly demonstrates OSHA’s lack of real world understanding of the construction industry and raises serious questions about their ability to responsibly craft industry standards,” says ABC Vice President of Government Affairs Geoff Burr. “We hope that this report will lead OSHA to withdraw its proposed rule and work more closely with the construction industry to emphasize compliance with the current standard.”

“These errors raise serious and significant questions about many of the other assumptions the agency relied upon in crafting its new rules,” says Stephen E. Sandherr, the chief executive officer of the Associated General Contractors of America. “We need measures in place that are going to allow all of us to continue the significant improvements in silica safety the industry has made, and the sad truth is that the agency’s rule is too riddled with errors to do that.”

“The assumptions that were made by OSHA in developing this rule are completely off base and we hope this report adequately tells the truth of what this rule will truly mean to the construction industry. We believe the current silica rule has done a fantastic job of reducing related illnesses so much so that it is still declining every year and current projections have it being eliminated over time,” according to Jeff Buczkiewicz, president of the Mason Contractors Association of America. “Our industry needs a rule that is based on real world construction site scenarios that is not technologically and economically infeasible to implement and this report clearly shows that this rule does not fit that bill.”

Ladder Clamp Allows for Safer Access

The SLATOR tool fastens to a steep slate or asphalt shingle roof and firmly clamps a ladder into position.

The SLATOR tool fastens to a steep slate or asphalt shingle roof and firmly clamps a ladder into position.

Falls are the leading cause of injuries and death at the workplace. In fact, according to OSHA, falling accounted for nearly 37 percent of all deaths in 2013 and is listed among constructions “fatal four.” Roofing professionals have always been particularly vulnerable to this danger. The inventors of SLATOR hope to change this. “We look forward to the day when falling off roofs was something that used to happen,” says Ronny Roseveare, co-owner of SLATOR.

A team of three remodelers/roofers from Lynchburg, Va. made a commitment to safety when they began their business in 2013. “In order to do the job right, we have to figure out a way to be safe,” says Roseveare. Between busy days working on houses, they began perfecting their approach to safety. Soon the Secure Ladder And Tie Off Responsibly, or SLATOR, was born.

OSHA compliant and ANSI certified, the thoroughly tested SLATOR tool fastens to a steep slate or asphalt shingle roof and firmly clamps a ladder into position, allowing any tradesman working on a roof easier and safer access to perform their work.

New USG Packaging Is Less Complicated

Beginning in early 2015, you may notice a change to USG’s packaging. USG’s products aren’t changing due to the new packaging. They still deliver the absolute highest level of quality, backed by USG’s unparalleled service and support. Thanks in part to OSHA mandates for warning statements on packaging, the new USG packaging is less complicated and easier to identify for your specific needs.

New USG packaging highlights include:

    Clarity: A uniform layout and presentation of key information makes it easier for you to find the right product for their needs.
    Consistency: Our new packaging is aligned within and across product lines, making it easy to identify USG products in retail, in warehouses and on job sites.
    Confidence: Easy-to-understand safety information and instructions protects against mishaps.
    Compliance:All new packaging meets or exceeds government regulations for GHS (Globally Harmonized System of Classification and Labeling of Chemicals) labeling.
    According to the regulations, after June 1, 2015, we can no longer ship products affected by GHS that feature the old packing. And on December 1, 2015, retailers and distributors can no longer sell products affected by GHS that feature old packaging.

Together, we can transform this mandated change into an opportunity to create a better experience for customers.

Our Company Culture: Safety Is Priceless All Year Long

Safety is Tualatin, Ore.-based Columbia Roofing & Sheet Metal’s No. 1 core value and a year-round commitment that streams through our entire operation. Just one very small diversion from the rules can cost someone his or her home, business or life. I sleep easy knowing everyone is home safely at the end of the workday.

Employees in the field perform a “Stretch and Flex” activity every morning, led by the foreman, to help prevent injuries.

Employees in the field perform a “Stretch and Flex” activity every morning, led by the foreman, to help prevent injuries. PHOTO: Columbia Roofing & Sheet Metal

There are key processes we follow at Columbia Roofing & Sheet Metal to ensure job safety:

Every two weeks our employees train with a paid outside safety training consultant, Integrity Safety of Vancouver, Wash. OSHA comes to our facility and our job sites if we have any questions. We keep up on the safety regulations and strive for perfection through staff member Pete Perrin and our safety consultant. In addition to all the safety rules that state and federal OSHA requires, we go beyond in many areas that just make sense, such as tagging all safety equipment, including ladders,
fall-protection equipment, first-aid kits and fire extinguishers, each quarter. Our employees, in the field and in the office, are held to a very high level of responsibility.

Each quarter we have a mandatory “stand down”, much like a military operation. This is when everyone stops all activities and inspects all job-site gear. We examine electrical tools, cords and equipment for proper function and wear and tear. Gear is tagged according to the color of the season as required by OSHA. Additionally, all ladders are inspected and tagged for acceptance. We exchange all our personal fall-protection equipment with each other and have it inspected in accordance with OSHA requirements. It is then tagged with the proper-color tape and worn; damaged equipment is replaced.

In addition, Columbia Roofing & Sheet Metal holds a mandatory “Save A Back” training every two years. Everyone, including me, attends a half-day of training on a Saturday. Save A Back is a program that began in New Zealand more than 30 years ago. It explains how to properly lift and focuses on workplace movement design, not just lifting with your legs. This makes it very different from many techniques taught in the U.S. Our employees in the field also conduct a “Stretch and Flex” activity every morning, led by the foreman, to help prevent injuries. Our foremen have been trained via Save A Back, and all the activities we engage in with our employees are moves taught by Save A Back.

All these efforts not only have helped us at work, but also benefit us in our daily lives.

In fact, our employees are encouraged to take safe practices home with them. We encourage personal-protective equipment and processes even when off the clock doing household chores. It is easy to skip following work-safety practices when off the clock, but we explain that everything we teach is for our employees and their friends to take home; it is the Columbia way!

I believe these rigorous safety standards have helped our company achieve a great insurance program and better customers who require low insurance modification rates (mod rates) on workers’ compensation. It also shows our customers we are serious about their safety, as well as ours. We have had two OSHA fines in 18 years in the roofing business. I believe this shows we are “walking the talk”!

We have found being safety conscious is also profitable. You are never “money ahead” making sacrifices related to safety. We spend less time processing claims, talking with lawyers and families, doing light-duty work, dealing with OSHA and losing customers over safety issues. The value of sending home employees and customers to their families in a healthy way—every day—is priceless.

NRCA Awarded $137,000 OSHA Grant, Will Conduct Fall-protection Classes in Coming Year

The Rosemont, Ill.-based NATIONAL ROOFING CONTRACTORS ASSOCIATION has been awarded a $137,000 grant through the Occupational Safety and Health Administration’s Susan Harwood Training Grant program. The grant will enable NRCA to continue to conduct its successful Roofing Industry Fall Protection A to Z course free of charge for a year and will include classes taught in Spanish.

“NRCA is acutely concerned with preventing roof-related falls. This OSHA grant has been and continues to be vital to that pursuit,” says Tom Shanahan, NRCA’s associate executive director of risk management. “It allows for one-on-one hands-on fall protection and prevention training that is importantly roofing-specific.”

Roofing Industry Fall Protection A to Z is a one-day class that provides updates about fall-protection systems and includes current OSHA state-plan requirements. It also features hands-on equipment demonstrations and techniques for self-rescue and relief of suspension trauma.

NRCA will conduct 12 classes in eight cities, including four classes in Spanish. View dates and locations at RoofingMagazine.com/events.

The Susan Harwood Training Grant Program provides grants to fund education and training for workers and employers to help them recognize workplace safety and health hazards, implement injury and illness prevention measures, and inform them of their rights and responsibilities. This year, OSHA awarded $10,687,000 in grants to 78 non-profit organizations.

For information about NRCA and its services and offerings, visit NRCA.net.

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.

FOR CONSUMERS

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 CONTRACTORS

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.

REVIEW YOUR FALL-PROTECTION 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:

FALLS FROM ROOFS
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.

FALLS FROM LADDERS
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.

FALLS FROM SCAFFOLDS
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.

STAY AHEAD OF OSHA

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 Extends Comment Period for Proposed Workplace Injuries and Illnesses Rule

The OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION is extending the comment period on the proposed rule to improve tracking of workplace injuries and illnesses to Oct. 14, 2014. The proposal, published Nov. 8, 2013, would amend the agency’s record-keeping regulation to add requirements for the electronic submission of injury and illness information that employers are already required to keep.

During the public meeting held on the proposal, many participants expressed concern that the proposal may create motivation for employers to under-record injuries and illnesses because each covered establishment’s injury and illness data would become publicly available on OSHA’s website. Participants also expressed concern that the proposal would lead to an increase in the number of employers who adopt practices that discourage employees from reporting recordable injuries and illnesses. OSHA is concerned the accuracy of the data collected under the new proposal could be compromised if employers adopt these practices.

“OSHA wants to make sure that employers, employees and the public have access to the most accurate data about injuries and illnesses in their workplaces so that they can take the most appropriate steps to protect worker safety and health,” says Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels.

Therefore, OSHA is soliciting comments on whether to amend the proposed rule to require that employers inform their employees of their right to report injuries and illnesses, more clearly communicate the requirement that any injury and illness reporting requirements established by the employer be reasonable and not unduly burdensome, and provide OSHA an additional remedy to prohibit employers from taking adverse action against employees for reporting injuries and illnesses.

Individuals interested in submitting comments may do so electronically at Regulations.gov, the federal e-Rulemaking Portal. Comments may also be submitted via mail or facsimile. See the Federal Register notice for details.

A Roofer’s Guide to Safely Navigating an OSHA Inspection

Almost every American can recite his or her Miranda rights. We have all seen enough cop dramas and world’s wildest police chases on prime-time television to know that when the police, FBI or other law-enforcement agencies get involved that we have the right to remain silent, and we know that everything we say can and will be used against us in a court of law. Unfortunately, many roofing contractors in the construction industry do not remember their rights when an OSHA inspector arrives at their job sites, and this can lead to hefty fines. It is very important for residential and commercial roofing contractors to remember OSHA inspectors are adversaries when they visit your job site, and they are not inspecting your equipment and interviewing the crew out of curiosity. When an OSHA inspector arrives onsite, he or she is usually there to gather evidence to issue a citation.

One of the most discouraging situations that we have seen from OSHA’s recent push for larger fines and more citations occurs when honest men and women in the roofing industry open their arms to OSHA inspectors who arrive at the job. Roofing contractors and their crews are not criminals, and most truly have nothing to hide. The majority of contractors in the industry are hesitant to take a firm stance against an apparently well-to-do government agent on their job site. However, a roofer who opens up and allows OSHA inspectors free and unlimited access to a construction site is making a costly mistake. Therefore, it is important to remember that when OSHA visits on your next project, there are a few key questions that every roofing contractor needs to be able to answer about the inspection.

WHY IS OSHA ON MY JOB SITE?

OSHA will investigate a job site for a number of reasons. Inspectors will show up if an employee has issued a complaint against you, if there is a recent fatality or if there is an imminent threat identified. However, in recent months, OSHA has been after
the residential and commercial roofing industry through a systematic targeting method. The dangers of fall-related injuries in the industry have been well-documented, and this has prompted inspectors in your area to be on the lookout for roofers. Additionally, roofers are the easiest to cite due to the fact that roofing is a highly visible construction trade and an inspector does not have to use much effort to determine the likelihood of a dangerous situation that needs inspecting.

DO I HAVE TO COMPLY? HOW SHOULD I COMPLY? WHAT HAPPENS IF I REFUSE OSHA ACCESS?

First and foremost, you need to know that OSHA has a legal right to inspect your job site. OSHA has what is called “administrative probable cause” to inspect and investigate your project. OSHA’s probable cause is more easily obtained than that of other agencies. An officer of city, state or federal law enforcement needs a much more specific probable cause to enter a private citizen’s property. When an active construction job is taking place, there is an inherent risk of danger and injury, and this gives OSHA all the administrative probable cause it needs.

This is not to say that you or your site superintendent does not have the right to deny OSHA access to the project and demand that the inspector get a warrant. The site superintendent has the option to consent to OSHA’s inspection or deny the inspector access to the project. The superintendent is well within his or her rights to tell the inspector to get a warrant. This is not an easy fix, however. If you tell OSHA to get a warrant, it most certainly will. Because of OSHA’s broad power to oversee safety within the U.S., the agency can obtain a warrant from a judge or magistrate. Once OSHA obtains a warrant for a site inspection, its inspection can become much more invasive. This means OSHA inspectors can get permission from a judge to examine documents; conduct extensive interviews; and also perform scientific tests on items, such as air quality, presence of combustible material or any other danger.

The bottom line is that it is rarely a good idea to tell an OSHA compliance officer to get a warrant. The reasoning behind this has to do with the scope of OSHA’s inspection rights under the Code of Federal Regulations (CFR). The CFR demands that OSHA’s inspection be “reasonable.” This essentially means that the agency is limited to inspect only the men, equipment and materials that are within “plain sight.” “Plain sight” is a doctrine borrowed from criminal law and the Fourth Amendment, which says that a government agent may not sample or manipulate anything that is not within his or her reasonable line of sight. If an agent violates this doctrine, it is possible all the information he or she obtained during the inspection may be suspect.

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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:

ROOF OPENINGS

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.

SUPPLYING MATERIAL TO THE ROOF

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.

CONTROLLED ACCESS ZONES

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.

USING SAFETY MONITORS ON LOW-SLOPE ROOFS

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.

WARNING LINE FOR NON-ROOFERS

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.

ASSEMBLING AND INSTALLING ROOFS

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.