By Dan Hannan, CSP
From the August 2018 Issue
For over 20 years, falls from heights have been a principal source of serious injury and death in the workplace. Ladders, roofs, storage mezzanines, stairs, and loading dock platforms describe the most common places where people are seriously or fatally injured from falling. It doesn’t matter whether erecting steel on a new 30-story building or performing common maintenance for a school, the consequences following a fall are often life-changing.
For facility managers, rooftop environments pose big risks. The Occupational Safety and Health Administration (OSHA) requires employers to identify and prevent workers from being exposed to fall hazards of six feet or more while performing construction activities, and of four feet or more while completing routine maintenance tasks. Facility owners employing contractors to perform work on roofs share similar obligations through OSHA’s multi-employer citation authority. In these cases, the facility owner is viewed as the “controlling employer” and is subject to the same fines/citations received by the contractor.
It’s fairly obvious what the benefits of prevention are, and that’s where the bulk of the effort and resources needs to be placed. Just talk to any employer that’s gone through a workplace fatality, and they openly admit that the human cost, and subsequent business costs, are not worth short-changing prevention. OSHA citations, increased insurance premiums, personal hardship, and a nightmare of publicity should be enough of a deterrent when accounting for safety in annual budgets.
On average, 650 workers die from falls each year (about 15% of all workplace fatalities), according to OSHA. And workplace injuries costs employers more than $170 billion each year.
Unprotected roof edges, hatchways, fixed ladders, and even skylights must be properly protected to ensure no one suffers a fall. While prevention seems as simple as “stay away from the roof edge,” the risk remains in the form of satisfying OSHA requirements and also following your own advice. As challenging as it is to control our own behavior the risk compounds exponentially when contractors are allowed access to a roof to perform work.
Roof Maintenance Safety: Engineering And Process Controls
The solution for preventing falls during roof maintenance and other work on a roof is straightforward and achieved through both engineering and process controls. The idea is to make things as simple and as easy as possible so human error has the lowest chance of entering into the equation. When proper equipment and processes are used these offer a one-two punch to ensure that when people go up they come down safely. Employers have found that the use of both engineered fall protection systems and written protocols, such as a rooftop management plan, offer the greatest reduction of risk.
Engineering For Safety. Here is a look at the pros and cons of the two most common engineered rooftop safety systems:
- Personal fall protection
Personal fall protection systems require workers to be tied or tethered through a combination of a body harness and a lifeline attached to a fixed anchorage point on the roof. These systems are meant either to restrain the worker from getting too close to an edge/opening or to stop them from falling to the ground should they go over the side.
Considerable training, inspection, and maintenance is associated with personal fall protection systems, and these rely on the worker to consistently use the equipment correctly. When several workers are working in one area work performance may be hindered as lifelines can become entangled. Fall protection equipment, though, is portable and can be used elsewhere in a facility where fall hazards exist. Portability and maneuverability of this equipment allows for fall protection where a guardrail cannot be erected.
Guardrail systems are commonly engineered out of steel and to OSHA specifications. These can be erected either temporarily or permanently around roof edges, hatchways, or other areas where potential for falls to a lower level exist. Installation at the roof edge allows work to be freely performed at the edge and entirely within the guarded area without use of other fall protection devices.
Process Controls For Safety. Regardless of who it is or why a person goes up on a roof their activities need to be accounted for and controlled. OSHA requires employers to protect their employees from all recognized hazards wherever they exist which includes unseen areas like rooftops. Taking control of how the work on a roof is performed is a risk reduction practice. A rooftop management plan establishes a process that controls rooftop activities by accounting for the following:
- How access will be made (ladder, aerial lift, stairwell)
- The nature of work to be performed, timeline, and what equipment will be used
- What fall protection systems will be used
- Required training in fall protection systems, hazard recognition, and granting access to only those who are authorized
- Describe what actions will be taken in the event of an emergency such as removing an injured person from the roof or someone dangling from the side.
These types of roof management plans are often implemented at the contractor work assignment stage. When a facility hires a contractor to perform work, the rooftop access control requirements would accompany work authorization.
School Case Study
The facility maintenance team at a large public school district in Minnesota is responsible for a long list of building maintenance items that requires routine visits to rooftops. Inspection or repair is necessary to equipment including roof drains, HVAC units, cameras, satellites, vents, fans, exhaust units, ladder access, roof hatches, etc. Many of these items are located near roof edges.
This presented fall risks to not only school district employees but also to the contractors frequently hired to perform repairs. The buildings lacked engineered and certified anchorage points for personal fall protection. However, this would require installing anchorage points into a structural member of the roof. The district was concerned about penetrating the roof liner and water intrusion, so a non-penetrating solution was requested that would not void the roof warranty or penetrate the building façade.
Based on these criteria the most appropriate solution was a guardrail system that offered fall protection directly at the point of access to the roof from a fixed exterior ladder (seen above). The guardrail system consisted of a combination of guardrail panels, weighted bases, and spanners. The system was constructed at the roof edge preserving the freedom of movement over the entire roof. Hatchway and skylight exposures were also addressed in the same fashion.
Facility managers have a responsibility to protect those performing work at heights including roofs. Injury prevention is achieved through the application of engineering and process controls. This holistic approach provides effective risk management that only requires a commitment to the resources to make it happen. A third-party safety consultant may be helpful in evaluating which fall protection solution is most appropriate.
A Certified Safety Professional, Hannan is director of environmental, health, and safety for Hilmerson Safety Services, a professional safety services and consulting firm based in Savage, MN. Hilmerson educates clients of various OSHA regulations and the adverse impact that accidents or injuries may have due to non-compliance with governing regulations.
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