NRCA Addresses OSHA’s Final Rule Governing Workplace Exposure to Crystalline Silica

William A. Good, CAE, vice president of NRCA, states: “Based on our initial review, NRCA has serious concerns regarding OSHA’s new silica regulation. First and foremost, we are concerned the final regulation significantly will increase fall hazards for roofing workers by requiring contractors to implement engineering controls that are not suited to work performed on sloped roofs. We are also concerned the rule will add significant new compliance costs for contractors that OSHA continues to seriously underestimate. Although we continue to have serious concerns, we appreciate OSHA made modest improvements in the final rule in response to concerns we articulated in testimony on the regulation as originally proposed.

“NRCA submitted detailed comments to OSHA in response to the initial proposed regulation released in 2013 and also testified at a hearing on the proposal in April 2014. Additionally, NRCA representatives met with officials in the Office of Management and Budget in February 2016 to reiterate these concerns as the final silica regulation underwent its final review.

“When it becomes effective for the construction industry in June of 2017, OSHA’s final silica regulation will dramatically reduce the permissible exposure level [PEL] for silica in construction workplaces to 50 micrograms per cubic meter (from the current 250) and will establish an action level of 25 micrograms per cubic meter. To meet these much lower levels, new engineering controls will become necessary to ensure compliance. With respect to roofing work, this likely will require workers who face even minimal amounts of exposure to silica dust to use wet cutting methods and dust masks.

“NRCA is most concerned the new requirements will increase the risk of falls for roofing workers. Under the new rule, workers in many cases will have to use wet saws on the rooftop, introducing new hazards, such as slipping on wet surfaces and tripping on hoses. We call on OSHA to work cooperatively with us to identify implementation strategies that protect workers from the new fall hazards created by the rule.

“Despite some improvements in the final rule, NRCA continues to be concerned compliance with the regulation may not always be technologically feasible and will cause much uncertainty for employers. For example, some commercial laboratories have indicated they are not capable of measuring workplace silica levels with accuracy or consistency at such low levels.

“NRCA leadership and staff will continue reviewing the 1,772-page final rule issued March 25 to determine and analyze the potential effects on the roofing industry and will provide further information and guidance for members in the future.”

Prefabricated Edge Metal Helps Shape Unique Roofs on a Georgia Hospital

To expand its services and make it easier for patients and visitors to navigate its facility, Gordon Hospital, Calhoun, Ga., underwent a $37 million expansion. The project added 59,000 square feet of hospital space, renovated 11,500 square feet of space, and created a new patient tower entrance to separate inpatient and outpatient service entrances. The various aspects of the project included 11 different roof areas, so the project’s general contractor, the Atlanta office of Birmingham, Ala.-based Brasfield & Gorrie, brought Atlanta’s Diamond Roofing Co. into the project during concept design.

The architects designed all the curves and unique walls to make the campus beyond ordinary and give the hospital a certain appeal.

The architects designed all the curves and unique walls to make the campus beyond ordinary and give the hospital a certain appeal.

“The hospital addition and renovation was still just a sketch and a narrative, and we worked together to understand the owner’s needs and architect’s intent,” says Dave Mossige, Diamond Roofing’s president. “Roofing systems have be- come very complex over the years and it really does take a roofing specialist to navigate the numerous options and decide the best roofing systems for the project.”

Having the roofing contractor onboard from inception also helped with staging. When it became apparent that two canopies between the new and existing buildings would pose significant challenges with materials’ access, the team was able to plan ahead and stock-pile materials near the area months pri- or to needing them.


Because this was a fast-track project, 10 to 15 crew members worked across multiple roof areas. “All the other trades come in behind us once we have the roof ready, so getting the roof area dried-in was key to the schedule,” Mossige says. “That’s why we chose a more durable two-ply modified bitumen rather than a single-ply system for the roofing. Disturbances that happened to the base while the trades were working off the roofs could be quickly and easily repaired before we applied the cap sheet.”

The roofing areas added up to 25,400 square feet of space, including the main roof, penthouse and various other canopies. The main roof on the new addition was unique because it was divided into two portions: one with a steel deck and another with a concrete deck for future vertical expansion. The concrete deck was 5-inches higher than the steel deck.

To make the steel deck meet the thickness of the adjacent concrete deck for a level roof, Diamond Roofing’s team mechanically fastened 5 inches of polyisocyanurate insulation on the steel and then installed a 1/4-inch-per-foot-total tapered ISO system. The team then applied a cover board to increase the system’s wind rating and provide better adhesion of the base ply. The tapered system and cover board were set in ribbons of low-rise foam adhesive. The next layer was an SBS modified bitumen as a cold-process adhesive and then a fire-rated granular cap sheet, also set in a cold-process adhesive.

Although Diamond Roofing has a sheet-metal shop in which team members fabricate edge metal, it worked with a supplier to source prefabricated edge metal that had been formally tested to meet or exceed the hospital's required FM 1-105 criterion.

Although Diamond Roofing has a sheet-metal shop in which team members fabricate edge metal, it worked with a supplier to source prefabricated edge metal that had been formally tested to meet or exceed the hospital’s required FM 1-105 criterion.


Although Diamond Roofing has a sheet-metal shop in which team members fabricate edge metal, most of the roofing firm’s product is equivalent to a wind rating of FM 1-60 and FM 1-90. FM approval ratings apply to uplift pressures in pounds per square foot. Hospitals are constructed to stricter standards, however, and officials at Gordon Hospital wanted to ensure an FM 1-105 approval rating. Diamond Roofing worked with a supplier to source prefabricated edge metal that had been formally tested to meet or exceed the FM 1-105 criterion.

The ability to order the sheer volume of edge metal needed also saved time on the project. “We had over 2,500 lineal feet of edge metal on this project. That would’ve taken us three weeks to fabricate,” Mossige explains. “In addition, the highly unique specifications of the edge metal needed for the project made it more cost-effective for us to outsource it.”

The edge metal needed to be a heavy gauge of 0.063 prefinished aluminum with a protective Kynar 500 resin-based coating. The architects also wanted welded mitered corners. In certain places on the roofs, unusual radiuses and slopes—occasionally joining with straight coping at offset angles—meant some inside and outside miters had to be exactingly produced for odd angles like 104 and 140 degrees.

For example, on one parapet, two different elevations come together at a corner, making precision critical for the manufacturer and installer. “When you are dealing with preformed metal, you have to be precise,” Mossige notes, “but when you’re doing a raised, offset miter, you have to be perfect.”


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Safety Week Seeks to Raise Awareness at Job Sites

More than 50 national and global construction firms have joined forces for the annual Safety Week, a construction industry-wide education and awareness event. Safety Week 2016 will be held May 2-6 to align with what the Occupational Safety and Health Administration and other federal agencies have set as the National Safety Stand-Down focusing on fall prevention on the job.

Safety Week is an opportunity for people and companies—even competitors—to work together and rally around a common cause. During Safety Week, construction companies will take the opportunity to thank their employees for the commitment to safety and work to educate, inspire and share best practices. Many companies will conduct on-site safety awareness activities.

“Ask anyone in construction and they will tell you that safety is the No. 1 priority—it crosses competitive boundaries and ties us all together,” says Ross Myers, CEO, Allan Myers and Safety Week co-chair.

“That is the reason we’ve chosen Safety Ties as our theme this year, because the commitment to safety is strongest when it’s woven into the culture of our work and is a visible part of our everyday routines and processes. For workers on a job site, this starts with the individual. Every day, each person needs to take responsibility for their own safety and the safety of those around them.”

To symbolize Safety Ties, participating companies will launch social media campaigns around photos of bootlaces as a visible homage to Safety Week.

Three major U.S. construction sites will host ceremonial events during which the laces and a “ribbon tying” will be used as powerful emblems of safety.

Job sites include:

  • The New NY Bridge (replacing the Tappan Zee), Tarrytown, N.Y. – featuring eight general traffic lanes, cashless tolling, and a shared-use path for pedestrians and cyclists.
  • The Crenshaw/LAX Transit project, Los Angeles – an 8.5-mile light-rail line, with eight stations, serving the Crenshaw District, Inglewood, Westchester and surrounding area.
  • The 35Express Project, Dallas, Texas – a $1.4 billion expansion of Interstate 35E between U.S. Highway 380 in Denton County and I-­635 in Dallas County extending approximately 30 miles, through nine cities and two counties to relieve traffic congestion. AGL Constructors, a joint venture between Archer Western Contractors LLC, Granite Construction Inc. and the Lane Construction Corp., in partnership with the design team of Parsons and HDR Inc., manages construction of the 35Express Project for the Texas Department of Transportation. The project is scheduled for completion in mid-2017.

At these events, guest speakers and project executives will speak about the status of their projects and the importance of and unifying nature of safety.

“A culture of safety starts at the CEO’s office and I applaud all the corporate executives who focus on safety as their essential product,” says LA Metro CEO Phillip A. Washington. “The end users of these great transportation projects understand that by caring for the safety of workers, we also care about the quality and safety of the entire system.”

Additionally, Safety Week activations will be held at many other job sites across the country.

NRCA and United Union of Roofers, Waterproofers and Allied Workers Jointly Support National Safety Stand-Down, May 2-6

The following is a joint statement attributable to William Good, CEO of the National Roofing Contractors Association, and Kinsey M. Robinson, international president of the United Union of Roofers, Waterproofers and Allied Workers:

“On behalf of the United Union of Roofers, Waterproofers and Allied Workers (UURWAW) and National Roofing Contractors Association (NRCA), we are pleased to continue our annual support for the National Safety Stand-Down to Prevent Falls in Construction, organized by the Occupational Safety and Health Administration (OSHA), taking place throughout the U.S. from May 2-6, 2016.

“The latest statistics from the Bureau of Labor Statistics show 69 workers in the roofing industry died in 2014 from falls that occurred as they were doing their jobs. Those numbers reflect 69 families that have been changed forever by the loss of a loved one—a spouse, father, mother, son or daughter whose death has left a void in the hearts of family and friends.

“The National Safety Stand-Down is an effort to focus company and worker attention on the significance of fall hazards in construction and emphasize the importance of effectively implementing fall-protection systems on every project. NRCA and UURWAW encourage their members and all involved in the roofing industry to participate in the National Safety Stand-Down by delivering focused fall-protection awareness toolbox talks at the start of each day during that week and throughout the year.

“NRCA’s Toolbox Talks regarding personal fall-arrest systems, skylight and roof openings, warning-line systems and ladder safety can be found by clicking here. In addition, NRCA and OSHA will co-host a webinar about roofing fall protection Monday, May 2.

Special materials developed by UURWAW about fall protection can be accessed online, as well.

“Let’s pledge to continue the efforts to increase awareness of fall hazards, not just that week but throughout the year so all workers are safe performing the critical, quality work they do and are able to go home to their families each day!”

Keep Job Sites Safe with Hard Hat Tethers and Lanyard Systems

Hammerhead Industries introduces its  line of hard hat tethers and lanyard systems.

Hammerhead Industries introduces its line of hard hat tethers and lanyard systems.

Dropped from aloft, a hard hat is a 1-pound unguided missile that endangers the entire work site. It’s an accident that can be virtually eliminated with Hammerhead Industries’ line of hard hat tethers and lanyard systems.

In the unfortunate event of a fall, a fall-arrest harness protects the worker, but as his hard hat continues its descent, a fall-arrest harness won’t protect the worksite. Designed for use with all fall-protection harness systems, the RT5-5601 and RT5-5602 Hard Hat Retractable Tethering Systems are weight-tested to safely secure all commonly used industrial hard hats. The main difference is how each attaches to the worker.

The RT5-5601 is easily attached with Velcro strap loops and cinches around the fall protection harness strap, ring or tri-bar while the RT5-5602 employs a threaded stud that securely attaches to a garment with structure such as coveralls or vest. The RT5-5601 and RTS-5602 use a sturdy, industrial-grade spectra/nylon line that extends up to 14 inches. For additional safety, they both feature a gentle 2.5-ounce retraction force that takes up any unused slack to avoid entanglement by keeping the lanyard close to the body.

When workers are ready to call it a day, Gear Keeper’s patented Quick Connect System allows the hard hat to be easily disconnected without completely removing the lanyard’s base. The third product in the Gear Keeper Hard Hat line is the cost-effective standard Hard Hat lanyard TL1-5001. The 20-inch loop mount uses a spring clip that attaches to a garment with structure, such as coveralls or vest.

OSHA vs. State Rules: Residential Fall Protection

The Washington, D.C.-based Occupational Safety and Health Administration has demanded some states that administer their own occupational safety and health agencies and enforce state-specific workplace rules adopt federal provisions related to residential fall protection. California, Kentucky, Oregon and Washington are four such states with provisions for residential fall protection that differ from federal OSHA’s. One of the federal requirements is that fall protection is required in roofing work at heights of 6 feet or greater. OSHA has singled out this requirement as one that the states must meet or OSHA will take over enforcement of all construction workplace rules.

Government statistics indicate state plan states that use a risk-based approach, where roof height is one of many factors considered when developing regulations, generally experience lower worker death and injury rates than comparable federal states.

The recent release of initial workplace fatality numbers by the Bureau of Labor Statistics, Washington, for 2014 has again brought the issue to the forefront and prompted the following Jan. 29, 2016, response from NRCA CEO William A. Good to Dean McKenzie, OSHA’s acting director of construction.

Dear Mr. McKenzie:

We are, of course, incredibly disappointed that you choose to carry on with your plan to impose federal rules, developed over the objections of the roofing industry, on states that have had considerable success with their own fall protection regulations. Those regulations have been developed, for the most part, with the ac- tive involvement of health and safety agencies, management and labor in the affected states. What’s more, in most of the states you cite as being deficient in meeting the federal “effectiveness” standard, the rate of accidents and fatalities from falls in construction is consistently better than it is in comparable states under federal OSHA’s jurisdiction.

And what’s even more incredible is that since federal OSHA unilaterally changed the rules for residential fall protection, the number of fatal falls has actually increased. OSHA’s promise that the cancellation of STD 3.1 in 2010 would make roofing workers safer has delivered the opposite result with 61 roofing workers killed by falls in 2012, 66 in 2013 and 69 in 2014. And yet OSHA marches on, unaffected by the facts.

How you can consistently ignore the data and instead rely on a vague definition of “effectiveness” is frankly beyond me, and makes absolutely no sense. It seems to me that an effective safety standard is one that actually works to protect workers from falls, rather than one that meets certain regulatory language.

In your letter you cite “standards that permit, for example, certain work to be performed at heights of 15 to 20 feet without positive fall protection.” As we have argued previously, the height of the roof is not the only issue that needs to be considered for effective fall protection. Rather, job-specific fall-protection assessment should take into account the type of building, the slope of the roof and the type of roofing materials being installed. This strikes me as being remarkably similar to the approach to safety Dr. Michaels, among others, has long advocated, but this approach is missing from OSHA’s heavy-handed efforts to impose federal rules on states.

In addition, if height were indeed the only issue, then perhaps you can explain why certain scaffolding operations are allowed up to 10 feet without fall protection, and why certain steel erection activities are allowed up to 30 feet without fall protection. And perhaps you can also explain why, over the period from 2010 to 2013, Texas had an average fatal construction fatality rate of 11.63, while California’s was 5.95.

The tragedy, of course, is that this isn’t just an academic conversation. Lives are at stake, and more are being lost in those states OSHA is responsible for than in those that have developed workable and, yes, effective, regulations.

I understand you choose not to meet with us to discuss this further. While I’m not surprised, I am left to wonder what is reasonably to be done to make roofing jobs safer. OSHA’s approach has made things worse, and you seem intent on just doing more of the same.

William A. Good, CAE
Chief Executive Officer
National Roofing Contractors Association

Data Can’t Replace a Commitment to Safety

I recently read a paper titled “Predictive Analytics in Workplace Safety: Four ‘Safety Truths’ that Reduce Workplace Injuries”, published by Pittsburgh-based Predictive Solutions. The company offers a variety of safety solutions to help customers improve and sustain their safety program results. The article stated that predictive analytics help many organizations gain insight into their operations and use their resources in the most effective way. These models predict the likelihood, frequency and location of workplace injuries using the customers’ safety-observation data.

How can workplace injuries be predicted? Predictive analytics draws real-time conclusions about future risk using safety-observation data. For instance, the company’s “Red Flag” model identifies projects, sites or work groups that show characteristics at a higher risk of incidents.

In addition, Predictive Solutions offers consulting services that drive culture and process change within organizations to create sustainable workplace injury prevention programs. In my experience, a company’s culture is the most important aspect in reducing workplace injuries. Predicting occupational accidents, incidents and injuries is great as long as an employer is willing to change its company culture. One does not need a library of data to determine there is a problem in a company. On the other hand, experience tells me that extensive OSHA citations, high EMR (Experience Modification Rating), high workers’ compensation premiums and high employee-turnover rates are indicators of a company in need of a safety program. How the ownership, management, and workforce view safety is the real key to preventing workplace incidents and accidents. A mountain of data is useless without a commitment to make changes within a company.

For data to make a difference in an organization, a safety program must be in effect in the company. A safety program primarily requires a firm commitment from the owners and top management, as well as buy-in from all employees and all levels of management.

Secondly, a written HASP (Health and Safety Plan) that documents the firm’s commitment should be in place. For help in developing a health and safety plan, a company can hire a consultant or a safety professional; contact the OSHA area office; or visit OSHA’s website.

In addition, training must be included in the program. This training must follow all the pertinent OSHA standards. The most important standards for the roofing industry to follow are fall protection, scaffolding and powered industrial trucks.

Finally, it is important to provide feedback through job-site audits and inspections. These inspections can be performed in-house by managers, supervisors or a safety professional. Through inspections, the company can determine if its program is working.

Collecting data for the sake of collecting data is absolutely useless without a viable documented safety culture. Training and inspection programs must also be in place to address the data that has been collected.

Tool Lanyard Protects Tools, Property and Workers Below

Werner Co.'s 15-pound Tool Lanyard was designed to complement a complete fall protection system and improve safety and productivity in work environments.

Werner Co.’s 15-pound Tool Lanyard was designed to complement a complete fall protection system and improve safety and productivity in work environments.

Werner Co.‘s 15-pound Tool Lanyard was designed to complement a complete fall protection system and improve safety and productivity in work environments.

The lanyard is made up of a stretch cord surrounded by durable webbing that is 30 feet long when retracted and can extend up to 50 feet making job-related tasks easier. It includes a carabineer and drawstring connection points so the user can attach the lanyard to a work belt or harness.

Built for tough environments, this heavy-duty lanyard can hold a max-working load of 15 pounds, suitable for most handheld tools.

Safety Railing System Provides Fall Protection around Roof Hatch Openings

The BILCO Co. has introduced the BIL-Guard 2.0, the second generation of its safety railing system.

The BILCO Co. has introduced the BIL-Guard 2.0, the second generation of its safety railing system.

The BILCO Co. has introduced the BIL-Guard 2.0, the second generation of its safety railing system. The BIL-Guard 2.0, like its predecessor, is a fixed railing system that provides a permanent means of fall protection around roof hatch openings. The new and improved model will be available this summer and boasts aluminum construction for increased strength and rigidity, a redesigned self-closing hinge and positive latching system, and stainless steel hardware throughout. The product is available in mill finish aluminum and with a safety yellow powder-coat paint finish.

Also compliant with OSHA fall protection standards (29 CFR 1910.23), the BIL-Guard 2.0 features an innovative mounting system that does not penetrate the roofing membrane. The new system is easy to install and does not require special training or certification for proper installation. The design features quick-mount curb brackets for a fast, secure attachment and pivoting mounting sleeves with compression fittings to lock the railing system into place. The BIL-Guard 2.0 is also equipped with a standard self-closing gate to maintain continuous fall protection to ensure that OSHA compliance is preserved.

BlueWater to Showcase Solar-powered Warning Light at IRE

A provider of modular guardrail systems and passive fall protection systems, BlueWater Manufacturing Inc., a Safety Products Group company, will be exhibiting at the 2016 International Roofing Expo (IRE), taking place Feb. 17-19, 2016, at the Orange County Convention Center in Orlando, Fla.

The International Roofing Expo is an annual trade show and educational conference where all segments of the roofing construction and maintenance industry come together for three days of face-to-face interaction, product review, education and networking.

BlueWater will be one of 1,100 booths exhibiting products, services and equipment for the roofing industry, including gutters, coatings/adhesives, built up, fasteners, machinery, metal, modified bitumen, roof pavers, renewable energy, walkways/ballast, shingles, slate, solar, spray polyurethane foam, tile, ventilation, waterproofing and more.

BlueWater will showcase its LumiGuard Solar-Powered Warning Light at IRE for the first time and promises to be an innovative and easy-to-install roofing safety product. The LumiGuard is a solar-powered warning light that can be easily installed onto current rooftop railings, gates, hatches, skylights and surrounding mechanicals.

“Our team is excited to offer this new and innovative product to the marketplace. LumiGuard adds a new dimension to roof safety during nighttime hours that just hasn’t existed until now,” says BlueWater’s vice president of Operations, Greg Kenton. “LumiGuard is easy to use and install for the end-user, and we’re proud to unveil it at IRE.”

For more information about BlueWater Manufacturing Inc. visit the company at booth No. 2407 at the 2016 International Roofing Expo, Feb. 17-19, 2016, at the Orange County Convention Center in Orlando.