Essentials

The Occupational Safety and Health Administration (OSHA) enforces a wide range of fall-protection rules for roofing workers. Approved methods of fall protection for residential roofing work were published in 1995 as an alternative to OSHA's fall-protection standard. Residential contractors should be familiar with the alternative rules. This article will review fall-protection rules, which can be found on www.osha.gov.

Requirements

OSHA's residential rules allow safety monitors and slide guards on roof systems with an eave height of up to 25 feet (8 m) and slopes up to 8-in-12 (34 degrees). Following are the specifics:

• For a roof slope up to 4-in-12 (18 degrees), a roofing contractor must use a safety-monitoring system that complies with OSHA CFR 1926.502 or roofing slide guards.
  
  
• If a roof slope is greater than 4-in-12 (18 degrees) and up to 8-in-12 (34 degrees), slide guards are required.
  
  
• For tile or metal roof systems with roof slopes up to and including 8-in-12 (34 degrees), a safety-monitoring system may be used as the sole fall-protection method instead of slide guards.

The requirements for slide-guard materials, configuration and installation are:

• For a roof slope of 6-in-12 (27 degrees) or less, slide guards must be constructed of 2- by 6-inch (51- by 152-mm) stock. No more than three rows of roofing material should be applied at the eave before installing the slide guards. Roof jacks or similar supports should be installed using nails long enough to withstand an employee sliding into the guard. A slide guard's face must be perpendicular to the surface of the roof, and slide guards must be in a continuous configuration along the eave.
  
  
• For a roof slope greater than 6-in-12 (27 degrees)—up to and including 8-in-12 (34 degrees)—2- by 6-inch (51- by 152-mm) slide guards installed along the eave must be used. Additional slide guards must be installed below each work area at intervals not to exceed 8 feet (2.4 m). The additional slide guards need not be continuous, but they must be long enough to protect the work area.
  
  
• Removal of slide guards is performed once the roofing material is installed to the ridge and the employee climbs down to the uppermost slide guard and removes it, repeating this process moving downward to the eave until all the slide guards are removed. Only when the roofing job is complete may the slide guards at the eave be removed.

Alternative style

These alternative procedures are available to employers for projects that meet OSHA's definition of "residential construction," which is "... where the working environment, materials, methods and procedures are essentially the same as those used in building a typical single-family home or townhouse and characterized by wood framing (not steel or concrete); wooden floor joists and roof structures where traditional wood frame construction techniques are utilized. In addition, the construction of discrete parts of a large commercial building—such as a wood frame, shingled entrance to a mall—may fit within the definition of residential construction where the characteristics listed above are present."

There is concern among some roofing contractors that the residential fall-protection guidelines don't adequately address removal of an existing roof system.

Under the alternative method, the eave slide guard must be in place during removal. The concern is that slide guards quickly become clogged with roofing debris and continually must be cleared to remain as effective footholds. The alternative is to have workers protected by conventional fall-protection measures, such as personal fall-arrest systems. However, doing so returns contractors to the original problems associated with personal fall-arrest system use on some steep-slope roof systems. Those problems include lifelines snagging on tile or metal systems or being caught in debris from the tear-off. Each job needs to be assessed for an appropriate approach to safety. OSHA regulations and guidelines are meant to provide guidance as a minimum. Contractors must determine the appropriate safe solution to the risk at hand.

If there is a deficiency in the implementation of the alternative procedures, an OSHA compliance officer can issue a citation.

The bottom line

You can obtain additional information about OSHA's fall-protection standards from NRCA's Web site, www.nrca.net. To read OSHA's interim fall-protection compliance guidelines for residential construction, click here. Also, NRCA has developed a comprehensive safety manual to assist contractors in implementing effective safety programs.

Leslie Kazmierowski is NRCA's insurance programs manager.