Fall protection in the roofing industry
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Fall Protection in the Roofing Industry. SUBPART. Fall Protection for Roofing. M. Overview. Relationship of Subpart M (Construction) with other OSHA fall protection requirements Fall protection requirements in Construction, Subpart M specifically for roofing activities

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Fall Protection in the Roofing Industry

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Fall Protection in the Roofing Industry


Fall Protection for Roofing



  • Relationship of Subpart M (Construction) with other OSHA fall protection requirements

  • Fall protection requirements in Construction, Subpart M specifically for roofing activities

  • Multi-employer citation policy

  • Q&A


Fall Protection for Roofing


  • Two approaches on safety for falls:

    • Fall Prevention– prevents employee from falling (e.g., guardrails, fall restraint systems, covers, skylight screens, warning lines, safety monitor)

    • Fall Arrest– safely catches employee after they have fallen and before they strike a lower level. (e.g., personal fall arrest systems, positioning device systems, safety nets)


Fall Protection


1st Question- Is the work being performed eitherinspection, investigation, or assessment prior to the start of construction work or after completion of the construction work?If it is, Subpart M does not apply and fall protection is not required during these activities.

Fall Protection Requirements


Fall Protection for Roofing


(Subpart M, 29 CFR 1926.500 – 503)

  • Most work 6 feet above levels to which you could fall (primarily based on type of work activity or exposure condition):

    • Ramps, runways, walkways,

    • excavations, hoist areas, holes,

    • formwork, reinforcing steel, leading

    • edges, unprotected sides or edges,

    • overhand bricklaying, roofing,

    • pre-cast concrete erection, wall

    • openings, residential construction, and

    • other walking/working surfaces.

Scope of Subpart M


Fall Protection for Roofing


  • Subpart M is like the general duty clause for fall protection in Construction (i.e., it covers fall protection when not specifically addressed by another standard).

  • For example, it does not cover:

  • employees on: scaffolds (Subpart L);

  • personnel platforms on a scaffold, crane or mobile equipment;

  • stairways and ladders (Subpart X)

  • following activities: steel erection (Subpart R), towers & tanks erection(1926.104), electrical power generation, transmission & distribution (Subpart V)


Fall Protection for Roofing


Fall Protection for Roofing Work

Roofing Work is defined in Subpart M as: hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including construction of the roof deck.

Subpart M covers fall protection for employees performing roofing work except when such employees are on equipment covered by another standard (e.g., scaffolds, personnel platforms, aerial lifts, stairways & ladders).

Employees involved in roofing work on steel erection sites are covered by Subpart R when such roofing work is performed during and as a part of the steel erection work (roofing material must serve as a structural component, such as could occur with some standing seam metal roof installs).

Holes (501(b)(4))- 2” or moreMORE PEOPLE FALL THROUGH ROOFS THAN OFF OF THEM!!!!

  • Protection must be provided as soon as hole is created; protection prevents employees from tripping in or stepping into hole or falling into hole by either:

    • Cover over

    • Guardrail around

    • Personal fall arrest system (PFAS) for employees

    • Restraint system to keep workers away from fall hazard

Hole Cover RequirementsAlso must provide falling object protection if employees below


Fall Protection for Roofing


  • Cover all floor, ceiling, or working surface

    holes, including skylights, that are larger

    than 2 inches.

- Must support twice the weight of loads imposed at one time.

- Secure from horizontal displacement.

- Marked “hole” or “cover.”

- Must cover hole as soon as created

Preventing Falls Through Roof Holes


Fall Protection for Roofing


Inadequate “cover”

Skylights or larger deck

holes can be covered,

surrounded by barriers or

have nets put underneath.


Fall Protection for Roofing


Floor/Deck Hole Covers

Secured? Clearly Marked?

Capable of supporting 2X weight imposed?

Protecting Openings/ Skylights & Bad Decking

  • Skylights

    • Requirements

      • Must be protected with:

        • 3/4” Plywood Covers

          • Twice the expected load

        • Tables

        • Fall Protection

        • Skylight Nets

        • Guardrails

Protecting Openings/ Skylights & Bad Decking

  • Skylight Protection

    • Tables

    • Covers

    • Nets

    • Flagged off


Hole Covers

PersonalFallArrest Systems

Guardrail Systems


Warning Line Systems

Safety Monitoring Systems

Controlled Access Zones

Fall Protection for Roofing


  • For roofing activities, Subpart M breaks down the allowed fall protective measures (other than for holes) into two categories:

    • residential 1926.501(b)(13)

    • non-residential 1926.501(b)(10 & 11)

Either provide conventional fall protection; i.e., PFAS, safety net, or guardrails; or follow the alternative protective procedures allowed (to be presented later).

For Non-residential roofing, alternative protective procedures are allowed only for low slope roofs (i.e., < 4:12). In other words, steep slope roofs require conventional fall protection ie. Guardrails, safety nets or personal fall arrest system. (501(b)(11)).

Basic Criteria for Both


Fall Protection for Roofing


Determining Slope

The run will always be twelve (12) inches

The following is an example of a slope measurement:

Rise = 2"

Slope = ------------------

Run = 12"



In this example, the slope is 2 and 12

Low Sloped Roofs

(4 and 12 or less)

Any roof with a slope of 4 and 12 or less is considered low sloped. Greater than 4 and 12 is steep slope.

The following fall protection systems can be used on a low sloped roof:

  • If < 50 ft width or less, then safety monitor alone is allowed (no mechanical equipment 502(h)(2)).

  • For >50 ft width, either:

    • Warning line and safety net

    • Warning line and guardrail

    • Warning line and PFAS, or

    • Warning line and safety monitor

Walkway to Work Area

  • Walkways must:

    • Have clear access

    • Protect against hazards

    • Designate area

    • Be reviewed with Crew

Guardrail System


  • Top rails must be between 39-45 inches high and withstand a lateral force of 200 lbs.

  • A midrail must be placed between the top rail and the work platform and be able to withstand a force of 150 lbs.

  • When using wire rope as a guardrail the following criteria must be met:

    • There must not be more than a 2 inch deflection when a force of 200 lbs. is applied against it in any direction

    • Top rail must be flagged every 6 feet

  • Must have a toeboard to prevent debris from falling off roof (if there is no parapet wall)

  • Must be a minimum of four feet on each side of a material handling area


Fall Protection for Roofing


Guardrail Requirements

  • Subpart M (1926.502(b))

Manufactured Guardrail Systems

This is one type of available guardrails for

use on flat roofs.

Too much Sag?


Fall Protection for Roofing



Toeboards prevent tools or materials from becoming falling objects.

Store materials minimum 10’ from edge.

Add screen or mesh if tools or materials extend above toeboards.

Personal Fall Arrest Systems(PFAS)


Fall Protection for Roofing



  • Components

If one of these parts fails, the system fails.

PFAS Anchorage Requirements


Fall Protection


  • Capable of supporting at least 5,000 pounds per attached employee or used as part of an PFAS that maintains a safety factor of at least ‘2’ (designed, installed and used under supervision of a qualified person).

  • Independent of any anchorage being used to support or suspend platforms.


Fall Protection for Roofing


PFAS Devices

Roof bracket

Rope grab on a

lanyard with

deceleration device


Fall Protection for Roofing


Sloped Roofing - PFAS



Fall Protection for Roofing


PFAS Devices

  • Limits fall to 2 feet or less

  • Must be attached directly

    to “D” ring on harness

    • Shock absorber may

      prevent lock up, or lead

      to ratchet effect.

  • Line must be protected

    from damage over edges.

  • Install and inspect in accordance with

    manufacturer; some will

    work horizontally,while

    some will not.

Watch swing hazards!

Self-Retracting Lifeline


Fall Protection for Roofing


PFAS Devices

Horizontal Life Lines- must be designed, installed and used under the supervision of a qualified person- maintain a minimum safety of factor of 2



Please continue to Fall Protection Part II

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