A wide net

You probably have come across the American National Standards Institute’s name when assessing and purchasing personal protective equipment, such as hard hats and safety eyewear. Under Occupational Safety and Health Administration rules, hard hats and protective eyewear used in construction must comply with one of several ANSI test requirements and pass test protocols.

OSHA compliance may be as effortless as ensuring hard hats and eyewear purchased for and used by workers have labels or markings reflecting manufacture in accordance with respective ANSI standards. But you may not be aware of the broader purpose ANSI serves in the safety and health arena and other ANSI standards that have been adopted covering a wide array of construction applications and operations, including low-slope roofing.

Background

Founded in 1918, ANSI is a private, nonprofit organization that administers and coordinates a broad inventory of voluntary U.S. standards. OSHA standards, in contrast, have the force of law because they are developed in conjunction with legislation (through the Occupational Safety and Health Act of 1970), and compliance with OSHA standards is mandatory.

ANSI facilitates standards development by accrediting procedures of industry stakeholder groups that serve as standards developing organizations. These organizations must meet ANSI’s criteria for integrity of process, balance, participation and consensus. Standards properly developed and approved then receive ANSI accreditation. Although voluntary, the significance of ANSI standards for roofing contractors is adhering to them often may be required by contract documents or referenced in OSHA regulations. For example, ANSI/ISEA Z87.1, “American National Standard For Occupational And Educational Personal Eye And Face Protection Devices,” and ANSI/ISEA Z89.1, “American National Standard For Industrial Head Protection,” are cited in Subpart E of the OSHA construction regulation requiring PPE.

ANSI standards

A common series of ANSI standards you should be familiar with is A10, “Construction and Demolition Operations.” The A10 standards committee’s scope includes standards relating to the protection of employees and the public from hazards arising out of, or associated with, construction and demolition operations.

The A10 committee is composed of a broad spectrum of members with collective expertise in every aspect of construction and demolition representing interests of unions, trade associations, contractors, academia, government, insurers and consultants. The scope of standards developed by the A10 committee ranges from those of universal application, such as public protection, to the esoteric, such as wind generation and turbine facilities.

You may find ANSI standards referenced in contract documents most commonly on new construction projects, but other projects may have general contractors or building owners citing them, as well. Some specific standards you may find referenced include:

• A10.6, “Demolition Operations”
• A10.24, “Safety Requirements for Low-Sloped Roofs”
• A10.32, “Personal Fall Protection Used in Construction and Demolition Operations”
• A10.34, “Protection of the Public on or Adjacent to Construction Sites”
• A10.38, “Basic Elements of an Employer’s Program to Provide a Safe and Healthful Work Environment”

One example of the interaction between OSHA regulations and ANSI standards that may affect enforcement is in the construction regulations in Subpart T, Demolition, 29 CFR §850-860. OSHA does not define demolition in that section or in the definitions portion of the construction regulations in §1926.32. However, in January 1994, an OSHA letter of interpretation states when a term is not specifically defined in OSHA regulations, the agency uses recommended standard definitions such as those set out in ANSI standards.

In this case, OSHA notes ANSI A10.6 defines demolition as “the dismantling, razing or wrecking of any fixed building or structure or any part thereof.” What makes this difficult from a contractor’s point of view is that nowhere in Subpart T is a mention of ANSI A10.6 made, so a contractor, looking for direction, must go to the ANSI standard. At the beginning of OSHA’s construction regulations is a section, 29 CFR §1926.6, “Incorporation by reference,” that identifies standards that are incorporated by reference into the provisions of the construction regulations. But A10.6 is not listed in that section, so you would have to be aware of a letter of interpretation or be familiar with other publications of similar standards organizations for provisions that might affect the enforcement of an OSHA regulation. This contrasts with ANSI/ISEA Z87.1 and ANSI/ISEA Z89.1, which are specifically cited in the body of the OSHA regulations making compliance simpler.

Safety programs

One area where many contractors look for assistance is in the development of company written safety programs. There are a few good templates available by some state-plan OSHA groups, but ANSI A10.38 is a valuable resource in this regard. The standard sets out the basic process of establishing a written program, including the initial task of identifying hazards and evaluating risks. Risk control in ANSI A10.38 follows the well-established principle of the hierarchy of controls, which universally applies engineering controls first followed by administrative controls with PPE as the last line of defense for worker protection.

A10.38 also sets out several program elements essential for inclusion such as regular worker training, employer commitment to safety, job-site inspections, accident investigation and disciplinary procedures. The standard does not include a sample program but offers a basic structure of a written program by setting out the critical elements that should be included.

OSHA regulations, by their nature, are intended to protect workers by requiring employers to put controls in place. An added benefit of those controls, in certain instances, often is a higher level of public protection, as well. But if you are looking for a resource singularly focused on minimizing or eliminating construction work-site hazards to the public, you should consult ANSI A10.34.

Some of the hazards addressed in the provisions of that standard include falling and windborne objects, machinery and vehicles, pollution and hazardous materials. Controls are set out for specific hazards that might affect the public, and the project constructor (the entity responsible for project supervision or control of work) is charged with developing a public hazard control plan. The plan is designed to ensure hazards are identified, responsibilities for hazard controls are assigned, workers are trained with respect to a contractor’s responsibilities and inspections are carried out to facilitate implementation of plan components. The standard does not include a sample plan for public protection; however, it includes a checklist aligned with the standard provisions that makes it simpler to execute the plan’s requirements.

One ANSI standard of particular interest to roofing contractors and one you may find referenced in project documents is ANSI A10.24, which applies to low-slope roofing.

ANSI A10.24 generally aligns with elements of OSHA construction regulations and the ANSI/ASSP Z359 Fall Protection Code, which is important for consistency with respect to fall-protection system requirements. In certain instances, the standard goes beyond OSHA requirements such as by setting out details for implementing a personal fall-restraint system, on which the OSHA construction regulations are silent.

NRCA staff currently is working on the subgroup charged with revising ANSI A10.24, and a final version likely will be circulated for a vote by the full A10 committee before the end of this year. The standard should be finalized and published by 2022.

ANSI A10 standards often contain requirements that elevate the level of hazard protection over regulations put in place by federal or state occupational safety and health agencies. Another example is the requirement for a greater quantity and higher classification of fire extinguishers during certain roofing work beyond what OSHA rules demand.

A higher standard

Remember, compliance with OSHA regulations always has been viewed as a low bar. And though compliance with OSHA is a huge step toward ensuring worker protection and establishing hazard controls, ANSI standards may fill voids in OSHA rules or provide enhanced levels of worker protection that have been vetted in a process equally demanding, if not more so, than government regulations.

ANSI standards can be an excellent resource if you are seeking to implement an initial safety and health program or build on your existing program with elements tailored to providing a greater level of worker protection. As with all areas of contract performance, you should review project documents to ensure you are not charged with complying with safety and health standards with which you are unfamiliar or that impose significant mandates that could increase costs or affect your usual work processes or protocols.

Harry Dietz is an author of Professional Roofing and an NRCA director of enterprise risk management.