As of June 16, 2011 OSHA passed a new compliance directive (STD 03-11-002) which eliminated the interim guideline that was established in 1995. This guideline allowed residential roofers to opt out of a conventional fall protection system if it proved to be infeasible or proposed a greater hazard. This dated directive opened the door for alternative methods of fall protection such as slide guards, safety monitors, and warning lines. However, with residential construction being down the past 2 years, the Bureau of Labor statistics has validated that as an industry, residential roofers should now have basic safety training with a strong emphasis on fall protection.
In 2008, the total number of fall fatalities were down, with the exception of steel erection and residential roofing. These two industries had a spike in fall deaths. Since the ruling was made in late 2010, residential roofers nationwide have been scrambling to decide if and how they will comply. This new compliance directive would resolve any misunderstandings that many roofers currently have and would require employers to comply with 1926.503(b)(13). This standard mandates that any worker engaged in residential roofing construction that is 6 feet off the ground (or above a lower level) must use conventional fall protection such as guard rails, safety nets or personal fall arrest equipment.
A large number of workers feel that this new OSHA ruling s simply a monetary stream for the government. However, the reality is the average fall of an employee could cost an employer at least $75,000+. And, should a fatality should occur, it could cost an employer $1.25 million+.
Having worked with home builders, roofers, and framers since the mid 1990′s , if there is one thing I find that runs consistent within the industry, it’s the need for a managed, comprehensive fall protection plan. While builders don’t typically get over 40’ off the ground, the average fall fatality occurs from 21 feet or less, a higher decked level or a lower obstruction.
This represents several problems:
The worker gets closer to the ground (but is still 6’ or higher on a roof) and they become complacent and not nearly as height sensitive as if they were 100’ off the ground.
The closer the worker is to the ground or at a lower level, it will not be as easy to determine how much room they have to properly arrest a fall.
OSHA estimates that at least 10% of all falls occur with some or all equipment available to the worker.
A misconception within the industry is that just by simply having the equipment means there will be limited or no chance of falling. This should not only satisfy the employer, but OSHA as well. Unfortunately, this belief is so widespread within the residential construction trade that OSHA feels a change is long overdue.
The industry does not seem to have a shortage of fall protection. There are 25+ manufacturers or self proclaimed experts who are able to provide a number of services on this topic. What our industry struggles from is the common residential contractor who does not take the time to develop and maintain a mandatory fall arrest plan for his workers. Under current conditions, the employer simply needs to claim that conventional fall protection is infeasible or creates a greater hazard and then provide a written plan detailing alternative fall protection methods .
Many industry experts feel that a healthy mix of solutions (OSHA approved equipment and alternative methods) would provide for improved safety without losing any height efficiency. In the hierarchy of fall protection, it makes the most sense to view these solutions as follows:
Fall Protection Hierarchy
Administrative Control
Personal Netting Guard Rail
Personal Fall Arrest Equipment
Safety Monitor/Warning lines
Fall Protection Equipment
Basic roofers kit consisting of single or mulch-use roof anchor, single D-ring harness, vertical lifeline (either 5/8” or ¾”) and shock absorbing lanyard with rope grab.
Fall Tech 7595A Basic Roofers kit
Same kit above only implementing a horizontal lifeline that will accept 1 or more users
Fall Tech 777075 horizontal lifeline
Fall Tech 7432 Heavy duty dual-truss roof anchor
Safety Monitor and warning line note: this option can only be employed for roof slopes up to 4/12 pitch and with a width no greater than 50’
Temporary Guardrail: see Bluewater and Kee Safety
Misc products: 7592A, 7595A, 7410, 7431, 7432, 7353, 7016, 7086L, 7479, 777075, 777050
Fall Protection Plans
Google fall protection plan samples/examples—show 2 – 3. Site specific plans
Detailing
Anchorage
Connection
Body Support
Rescue/Retrieval
Training Resources
falltechservicesgroup.com
lighthousesafety.com
Purchase equipment
BigDogSafety.com
