Falls are the leading cause of work-related injuries and deaths among roofers, this makes protecting roofing workers a priority. Working six feet or more above lower levels put roofers at risk for serious injury or death if they should fall. A lack of fall protection, damaged fall protection equipment, or improper setup will increase their risk of falling from height.

Fall Protection Training

Employers must provide fall protection training for all workers who may be exposed to fall hazards. The training must be conducted by a competent person and include information on how to recognize fall hazards and on what procedures to follow to minimize them (29 CFR 1926.503(a)). Training must address how to inspect, erect/disassemble, and maintain the fall protection equipment involved in the work (29 CFR 1926.503(a)(2)(ii)).  Retraining is required when previous training becomes obsolete due to changes in work conditions or fall protection systems or equipment. Retraining is also required when worker performance indicates a need for it (29 CFR 1926.503(c)).  Employers must certify that workers have been trained by documenting it in accord with 29 CFR 1926.503(b) – Certification of Training.

Using a Personal Fall Arrest System (PFAS)

Employers generally must provide fall protection if workers are exposed to a fall of 6 feet or more to a lower level. One form of fall protection is a personal fall arrest system (PFAS). When used properly, these systems will arrest a fall and prevent the worker from contacting a lower level. A PFAS consists of an anchor, a harness, and a lifeline or lanyard (usually with a deceleration device).

A PFAS must be used properly to be effective. Adjust the harness to fit snugly.  The D-ring attachment for the harness should be centered between the worker’s shoulder blades and the leg straps should be adjusted until they are snug.

Fall arrest systems must be designed and set up to prevent a worker from free falling more than 6 feet or contacting a lower level (e.g., the floor or the ground) (29 CFR 1926.502(d)(16)(iii)).

Body belts are not acceptable in a PFAS because they can cause serious injury during a fall (29 CFR 1926.502(d)).

The anchorage for a fall arrest system must be capable of supporting 5,000 pounds per worker attached or be designed, installed, and used under the supervision of a qualified person, as part of a complete personal fall arrest system that maintains a safety factor of at least two (29 CFR 1926.502(d)(15)).  During roofing work, it is important not to attach anchors to sheathing, single trusses, or most guardrails. These are typically not strong enough to meet OSHA’s standard. Instead of attaching anchors to sheathing alone, attach an anchor to a structural member by driving the fasteners through the sheathing and into the rafter or truss member below.  It is important to follow the manufacturer’s instructions when installing anchorage.

Employers must ensure that fall arrest equipment subjected to the forces of a fall are taken out of service until it has been inspected by a competent person and determined to be undamaged and suitable for reuse (29 CFR 1926.502(d)(19)).

How to Set Up a Personal Fall Arrest System

The length of the lifeline or lanyard, the position of the anchor, and the distance to the lower level are all important. Employers need to select equipment that permits workers to operate efficiently while limiting the distance they could fall.

Employers must properly calculate the fall clearance distance to ensure that a worker will not contact the lower level in the event of a fall (29 CFR 1926.502(d)(16)(iii)). And employers also need to evaluate the potential for a pendulum effect, which could swing a fallen worker into a nearby object. Swing-fall hazards can cause serious injuries, but they can be minimized by installing the anchorage point above the work area (i.e., up the roof slope from the worker) and setting up a maximum work range from the anchor point according to the manufacturer’s instructions.

Protecting Roofing WorkersThe total fall distance is the minimum vertical distance between the worker and a lower level that is necessary to ensure that the worker avoids contact with the lower level during a fall. It is important that employers calculate this distance before work begins to ensure that the proper fall protection equipment is selected for the location. To determine the total fall distance, several factors must be taken into consideration:

  • Free fall distance: The distance the worker falls before the PFAS begins to slow the fall. This distance must be 6 feet or less for a PFAS (29 CFR 1926.502(d)(16)(iii)).
  • Deceleration distance: The distance the lanyard stretches in order to arrest the fall. OSHA requires that this distance be no greater than 3.5 feet (29 CFR 1926.502(d)(16)(iv)), but it may be less for some PFAS equipment.
  • D-ring shift: How far the D-ring shifts and the harness stretches when it supports the full weight of a fallen worker, including the weight of tool belts and other attached equipment or tools. Employers typically assume this shift is 1 foot, but it can vary, depending on the equipment design and the manufacturer.
  • Back D-ring height: The height of the D-ring, measured as the distance between the D-ring and the sole of the worker’s footwear. Employers often use a standard distance of 5 feet for this height, assuming a worker who is 6 feet tall. The D-ring height needs to be adjusted for very tall workers, and for shorter workers as well.
  • Safety margin: An additional distance (typically a minimum of 2 feet) to ensure that there is enough clearance between the worker and the lower level after a fall.

Protecting Roofing Workers – Part II will be available on the blog next week!