Although federal regulations applica ble to fall protection in the roofing industry are complex, California recently amended its own fall-protection requirements. California's rules are comprehensive and apply differently depending on the type of roof system being installed.
Most roofing contractors are required to adhere to federal Occupational Safety and Health Administration (OSHA) rules even if their states are "state-plan" states—that is, states responsible for enforcing their own occupational safety and health rules. Most state-plan states incorporate federal OSHA rules into the body of worker safety rules enforced by their state agencies responsible for occupational safety and health. States under federal jurisdiction have OSHA rules enforced by a regional OSHA office.
California is a state-plan state that is active in pursuing worker health and safety issues, and California's Occupational Safety and Health Administration (Cal/OSHA) regulations are wide-ranging and, in many cases, more detailed than their federal counterparts. And though Cal/OSHA regulations may not apply to contractors outside California, such regulations may influence the federal rulemaking process, which makes it important for you to be familiar with them. A review of Cal/OSHA's amended fall-protection rules relating to roofing work follows.
A comparison
Although Cal/OSHA fall-protection regulations are similar to OSHA fall-protection regulations, you should be aware of important differences.
Cal/OSHA categorizes roofs (for purposes of fall-protection system alternatives) not only by slope but also by the type of roof system being installed. Built-up, single-ply and flat-seam metal roof systems are examples of "single-unit roof coverings." Asphalt, metal and wood shingles; wood shakes; standing-seam metal panels; asbestos-cement shingles; concrete and clay tile; and slate are deemed "multiple-unit roof coverings."
Fall-protection system options in Cal/OSHA construction safety orders are more specific than OSHA regulations. California's requirements for fall protection during roofing operations generally take effect at eave heights greater than 20 feet. However, certain roof application tasks make fall protection mandatory regardless of eave height.
For example, operating a felt layer or modified bitumen applicator with multiple torch heads—equipment that requires an operator to walk backward during operation—demands fall protection at any eave height. This type of equipment never is allowed on roofs with slopes greater than 4-in-12 (18 degrees).
Additionally, roofing workers on roofs with slopes of 4-in-12 (18 degrees) or less where single-unit roof coverings are installed at heights greater than 20 feet may be protected by warning lines. Cal/OSHA warning-line requirements are similar to OSHA rules. Warning lines must:
For work outside warning lines, on narrow roofs or on unusually shaped roofs, Cal/OSHA allows a "qualified person" to supervise roofing material application. OSHA rules allow a safety monitor without the use of warning lines on roofs with slopes of 4-in-12 (18 degrees) or less and 50 feet or less in width.
The following fall-protection systems for low-slope, single-unit roofs also can be used alone or in combination:
Under Cal/OSHA rules, when single-unit roof coverings are installed on roofs with slopes greater than 4-in-12 (18 degrees) at heights greater than 20 feet, workers must be protected by the following, alone or in combination:
The Cal/OSHA minimum 24-inch parapet height requirement is less than the minimum 39-inch parapet height required by OSHA.
It is important to note that to qualify as an approved state-plan state, the rules a state establishes must be at least as stringent as comparable federal health and safety standards. This constraint should be viewed in the broader context of state-plan regulations' overall effectiveness in providing a safe and healthful work environment rather than singling out specific provisions that may appear less or more restrictive than federal rules.
Cal/OSHA personal fall-protection strength requirements are similar to OSHA's in that anchors, lifelines and lanyards must be capable of supporting 5,000 pounds. But Cal/OSHA also has a specific fall-restraint regulation that sets an anchor-strength requirement of four times the intended load.
Catch platform and scaffold platform rules are similar in that both require a fully planked platform with protective guardrails at eave level. Eave barriers and railings with toe boards provide a top rail between 42 and 45 inches above a roof's surface; midrail halfway between the top rail and roof's surface; and nominal 4-inch-high toe board to protect workers from falling objects. Unlike catch platforms and scaffold platforms, no planking or platform is part of an eave barrier or railing system.
On slopes up to 5-in-12 (23 degrees) where multiple-unit roof coverings are installed at heights greater than 20 feet, Cal/OSHA requires the use of a roof jack system, 24-inch-high parapets or "equivalent protection."
A roof jack system, sometimes referred to as slide guards, uses roof brackets that are nailed through a roof deck into supporting rafters or truss members and a plank that is supported by the brackets and intended to stop a falling worker from sliding down a roof to the edge. "Equivalent protection" under Cal/OSHA likely could be accomplished using one of the previously mentioned fall-protection options for single-unit roof covering operations on slopes greater than 4-in-12 (18 degrees).
Cal/OSHA requires that workers installing multiple-unit roof coverings on roofs with slopes greater than 5-in-12 (23 degrees) and eave heights greater than 20 feet be protected by one or more of the following:
When roof slopes exceed 7-in-12 (30 degrees), Cal/OSHA requires workers be attached to safety lines when using roof jack systems.
Another new rule
A new Cal/OSHA construction safety order (Title 8, Section 1731 of the California Code of Regulations) that became effective April 1 affects production-type residential construction.
Cal/OSHA defines production-type residential construction as any new residential housing unit that is not a custom-built home or addition. The intended focus of the new rule is new construction (not reroofing) on tract-type, single-unit housing and condominium and apartment buildings. The rule mandates specific fall protection when eave heights exceed 15 feet and slopes are 3-in-12 (14 degrees) or greater. However, when roof slopes exceed 7-in-12 (30 degrees), the new rule mandates fall protection on applicable structures regardless of eave height.
Suitable methods of fall protection under the new rule include personal fall-protection systems, catch platforms, scaffold platforms, eave barriers, railings with toe boards and roof jack systems. When roof slopes exceed 7-in-12 (30 degrees), only personal fall-protection systems, catch platforms, scaffold platforms or railings with toe boards are suitable options.
The initiative behind this new rule is to match the fall-protection trigger height for production-type residential roofing operations with wood framing activities on production-type residential housing (which is effective at eave heights greater than 15 feet).
The new rule provides uniformity in fall-protection trigger heights for a majority of work performed during the early phases of production-type residential construction with the goal of simplifying and improving compliance. The rule has received broad support from many contractors, associations and unions in the residential construction community. Compliance is not anticipated to be difficult because the basic systems available for fall protection remain consistent; trigger height is the aspect that will require attention from field workers and those responsible for training and supervising those workers. Pre-job hazard analysis requires a review of plans and job sites to determine eave-to-ground distance and roof slope so proper fall-protection systems can be implemented.
Learn the rules
Roofing contractors working in California may be challenged by the complexity of Cal/OSHA regulations. Job sites may require a more wide-ranging review of rules and fall-protection options for compliance than is needed in other states. Contractors must review new Cal/OSHA fall-protection rules and new provisions related to tract housing; train workers to follow the rules; and possibly acquire additional fall-protection equipment to ensure compliance.
To access new Cal/OSHA fall-protection rules, go to www.dir.ca.gov/title8/1731.html. For more information about these rules and how to comply with them, contact me at (800) 323-9545, ext. 7502 or hdietz@nrca.net.
Harry Dietz is NRCA's director of risk management.
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