Facility Fall Protection: Roof and Facade Maintenance
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This document discusses facility fall protection for roof and facade maintenance. It covers common roof fall hazards and notes that roof fall protection is challenging due to various regulations and required abatement strategies. The document outlines OSHA regulations regarding safe distance requirements for roofing and non-roofing work. It also discusses common roof and facade hazards and strategies for hazard abatement, including engineering and administrative controls as well as personal protective equipment.
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Facility Fall Protection: Roof and Facade Maintenance
- 1. FACILITY FALL PROTECTION: ROOF & FAÇADE MAINTENANCE LJB WEBINAR – NOVEMBER 2012 MEG PHILLIPS, P.E., C.S.P. MPHILLIPS@LJBINC.COM; 513-582-4782
- 2. ROOF FALL HAZARDS 200 180 160 140 Roofs 120 Ladders 100 Scaffolds 80 Non-moving 60 vehicles StrucSteel 40 20 0 2002 2004 2006 2008 2010 Source: BLS Census of Fatal Occupational Injuries 2
- 3. BOTTOM LINE UPFRONT Roof fall protection is challenging ＞ Various regulations ＞ Abatement strategies You need a plan for: ＞ Access and safe distance policies ＞ Hazard identification ＞ Hazard abatement 3
- 4. AGENDA Safe distance Work classification Common hazards Abatement strategies ＞ Roof ＞ Facade Closing 4
- 5. SAFE DISTANCE? OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing 5
- 6. SAFE DISTANCE? OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing Proposed 1910 6
- 7. SAFE DISTANCE? OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing Proposed 1910 7
- 8. SAFE DISTANCE? OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing Proposed Mech. Equip. 1910 Exception 8
- 9. SAFE DISTANCE? OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing Proposed Mech. Equip. 1910 Exception 9
- 10. SAFE DISTANCE? OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing Proposed Mech. Equip. 1910 Exception 15 feet de minimis 10
- 11. OSHA 1910 OSHA 1910 does not provide a safe distance from the edge Proposed OSHA 1910 - Designated area ＞ Perimeter shall be erected no less than 10 feet from the unprotected side or edge 11
- 12. OSHA 1926: ROOFING OSHA (sec 1926.502(f)(1)ii) - “the warning line shall be erected not less than 6 feet from the roof edge which is parallel… not less than 10 feet…perpendicular to the direction of mechanical equipment operation.” Other exceptions: OSHA (sec 1926.500(a)(2) & 1926.501(b)(1-14)) ＞ Some leading edge work ＞ Precast concrete erection ＞ Residential construction 12
- 13. OSHA 1926: NON-ROOFING No safe distance OSHA letter of interpretation ＞ For trades other than roofing, warning lines at 15 feet will be a de minimis violation • Roofing Work and Other Trades on Low-Slope Roof (August 1, 2000) • Warning line at 6 feet for HVAC construction workers (November 15, 2002) 13
- 14. OSHA 1926: NON-ROOFING Warning lines must meet 4 criteria ＞ 15 feet or more from roof edge ＞ Meet or exceed OSHA 1926.502(f)(2) ＞ No work activity within 15 feet of roof edge ＞ Work rules prohibit workers from going outside warning line 14
- 15. INTERNATIONAL BUILDING CODE IBC (sec 1012.5) - “Guards shall be provided where appliances, equipment, fans or other components that require service are located within 10 feet of a roof edge.” 15
- 16. AGENDA Safe distance Work classification Common hazards Abatement strategies ＞ Roof ＞ Facade Closing 16
- 20. AGENDA Safe distance Work classification Common hazards Abatement strategies ＞ Roof ＞ Facade Closing 20
- 21. COMMON HAZARDS - ROOFS Means of access 21
- 22. COMMON HAZARDS - ROOFS Openings 22
- 23. COMMON HAZARDS - ROOFS Working near edge 23
- 24. COMMON HAZARDS - ROOFS Hoist areas 24
- 25. COMMON HAZARDS – FAÇADE Window cleaning and maintenance Architectural treatments Flags/banners 25
- 26. AGENDA Common hazards Safety requirements Abatement strategies ＞ Roofs ＞ Façades Closing 26
- 27. HIERARCHY OF CONTROL Elimination Substitution Engineering controls Effectiveness Administrative controls Personal protective equipment (PPE) Defeatability 27
- 28. LETTERS OF INTERPRETATION - OSHA Roof access openings require protection (July 12, 2000) ＞ Guardrail for roof hatch openings Fall protection requirements for roof construction (Dec. 15, 2003) ＞ Use of warning lines for low slope roof work vs. other trades 28
- 29. ABATEMENT OPTIONS - OSHA 29
- 30. OSHA STD 1-1.13 – DEFINITION Any surface designed or used as a walking / working surface ＞For tasks performed on a predictable / regular basis 30
- 31. OSHA STD 1-1.13 – REQUIREMENTS FREQUENT TASKS: ＞ More than 1x every 2 weeks ＞ More than 4 hours over 4 week period ＞ Required to use engineering controls (guardrail) LESS FREQUENT TASKS: ＞ Permitted to use alternative fall protection such as a personal fall arrest systems (PFAS) 31
- 32. AGENDA Safe distance Work classification Common hazards Abatement strategies ＞ Roof ＞ Facade Closing 32
- 33. ELIMINATION/SUBSTITUTION Place HVAC units on the ground Design considerations for roof access via aerial lift 33
- 34. ENGINEERING CONTROLS Guardrail ＞ Fixed ＞ Portable Lifts Fixed scaffold 34
- 35. ROOF PLAN 35
- 36. ROOF HATCH 36
- 37. ROOF FANS & SMOKE VENTS 37
- 38. SKYLIGHTS 38
- 39. ADMINISTRATIVE CONTROLS Roof permit system ＞ Primary vs. secondary control ＞ Implementation ＞ Training ＞ Monitoring 39
- 40. ROOF PLAN 40
- 41. THIS ISN’T WARNING LINE 41
- 42. DESIGNATED AREAS Proposed OSHA 1910 - Designated area ＞ Work of temporary nature such as maintenance on HVAC ＞ Use warning line as alternative to installing guardrails ＞ Surface slope must be 10 degrees or less ＞ Perimeter shall be erected no less than 10 feet from the unprotected side or edge ＞ Access to designated area must be clear path with warning lines 42
- 43. PPE Roof edge ＞ Fall restraint or arrest • Rail • HLL • Anchor points with lifeline 43
- 44. PPE: ANCHORAGE POINTS Fixed anchorage ＞ Structural steel? ＞ HVAC unit? ＞ HVAC curb? Temporary anchorage ＞ Ballasted anchor? 44
- 45. PPE SOLUTIONS Did you consider? ＞ Anchorage strength ＞ Fall clearance ＞ Swing fall ＞ Proper application ＞ Procedures and training ＞ Rescue 45
- 46. REVIEW What classification, safe distance and solution would you apply here? 46
- 48. AGENDA Safe distance Work classification Common hazards Abatement strategies ＞ Roof ＞ Facade Closing 48
- 49. FAÇADE MAINTENANCE Aerial work platforms Supported scaffold Suspended systems 49
- 53. INDEPENDENT ANCHORAGES Capable of supporting 5,000 pounds Located directly over the point of suspension 53
- 54. SUSPENDED SCAFFOLD ANCHORAGES SAFE POINTS Structural members determined by qualified person UNSAFE POINTS Standpipes Vents Other piping systems Electrical conduit Outrigger beams Counterweights 54
- 57. ANSI I-14.1 WINDOW CLEANING STANDARD Withdrawn by ANSI ＞ Revised standard being prepared by IWCA committee. Independent anchorage for suspension lines and lifelines Roof anchorage must be designed for the greater of 5,000 pounds or 4x the maximum applied load 15º rigging angle from point of suspension Annual anchorage inspection 57
- 58. AGENDA Safe distance Work classification Common hazards Abatement strategies ＞ Roof ＞ Facade Closing 58
- 59. ACTION ITEMS Evaluate your program’s safe distance policies Educate others about safe distances and work classifications Evaluate or develop a roof permit system 59
- 60. TO LEARN MORE Blog ＞ thespot.ljbinc.com/category/safety Past webinars ＞ Slideshare.net/kmesser Twitter ＞ @LJBInc 60
Editor's Notes
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- 15 feet or more from edge Meets or exceeds OSHA 1926.502(f)(2) No work activity within 15 feet of roof edge (between warning line and roof edge) Work rule prohibits workers from going outside warning line
- 15 feet or more from edge Meets or exceeds OSHA 1926.502(f)(2) No work activity within 15 feet of roof edge (between warning line and roof edge) Work rule prohibits workers from going outside warning line
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- The last consideration for roof fall protection is work classification. Different OSHA regulations apply to construction and maintenance activities, both of which often occur on roofs. Repairing or patching a roof would fall under general industry, while roof replacement would fall under the construction regulation. It is important to recognize this distinction and ensure you are applying the appropriate regulatory requirements to these different activities.
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- STD 1-1.13 – Fall protection in general industry If workers are exposed more than once every two weeks, or more than four hours over a four-week period, then engineering controls (guardrail) must be used as the primary fall protection. If workers are exposed less frequently, then you are permitted to use other means of fall protection, such as active fall protection which includes personal fall arrest systems (PFAS)
- STD 1-1.13 – Fall protection in general industry Definition of walking / working surface: Any surface used primarily as a walking / working surface Surface upon which workers are required or allowed to walk or work while performing assigned tasks on a predictable / regular basis.
- What classification, safe distance and solution would you apply here?
- Advantages: eng control, Dis: requires ground access, limited reach,
- Adv: eng control Dis: ground access, cost
- Adv: access from roof, permanent, work faster Dis:Use PPE, training, ongoing maintenance
- Back of this building is not accessible due to the grade. They changed the grade to allow aerial lift access as well as to permit scaffold to be built.
- Plenty of OSHA regulations and ANSI standards to provide general guidance Not going to attempt to explain all of them today, but be happy to answer questions Want to show some practical ways to AVOID fall hazards on roofs And why it’s important to do so I’ll start with that.