THE COHEN GROUP
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The Cohen Group Newsletter - Volume 6  Issue 1, Article 3.  January 2004

Safe Access and Fall Protection for Work on Roofs

Julie V. Wellings, CIH

Roofers (those who remove, install and replace roofing on buildings) are generally very familiar with the potential hazards and required protections when working on roofs. However, other trades (e.g., HVAC, electrical, etc.) and building maintenance staff must also work on roofs and may be less aware of the related safety requirements. This article will address both safe access and use of fall protection for work performed on roofs.

Interior roof access hatches are generally equipped with permanent fixed ladders; however, the hatch door can present a hazard. Such doors should be easily opened, secured and closed to minimize head injuries (from falling doors) and falls (from struggling with the door while standing on the access ladder).

Where there is no interior roof access, permanent fixed ladders should be installed on the building exterior as feasible. As such ladders are typically vertical (installed at a 90 degree angle relative to the ground), workers must use particular care in ascending and descending.

If portable ladders are used, they must be placed at a safe angle (at least 1 foot out for every 4 feet in working length) and must extend at least 3 feet above the point of support at the eave, gutter or roofline. Ladders must be secured (tied off) to fixed anchorage at the point of support, to prevent the ladder from moving side-to-side.

Ladder rungs must be kept free of mud and debris to prevent slipping. Tools and equipment should be carried in a tool belt and/or backpack, or raised by alternate means (e.g, rope) once the worker is safely on the roof.

Guardrails must be provided on roofs where there is a "routine need" for an employee to approach within 6 feet of the edge of the roof. Routine work is defined as work within 6 feet of the roof edge on more than four occasions per year; "intermittent" work is such work on not more than four occasions per year.

A parapet on the roof with a vertical height of at least 42 inches would be considered an adequate guardrail. When intermittent work is done, fall protection systems (e.g., safety harnesses, lanyards, etc.) may be provided in lieu of guardrails and must be attached to roof tie-backs or equivalent anchorage. Fall protection must also be worn whenever working on unprotected sloped roof surfaces steeper than 7:12 or 40 degrees.

This article summarized some of the most common issues relating to roof access and roof work but did not discuss all of the Cal/OSHA requirements or precautions that should be taken. Additional information may be obtained from the applicable Cal/OSHA regulations, e.g., Title 8 CCR Chapter 4 Subchapter 4 Article 24 (Fall Protection) and Subchapter 7 Group 1 (General Physical Conditions and Standards), or by calling us here at The Cohen Group.