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Fall Protection Systems for Roof Holes: OSHA’s Definition and Addressing the Risks

Fall Protection for Roof Holes

Fall Protection Systems for Roof Holes: OSHA’s Definition and Addressing the Risks

Roof holes pose a constant threat to the safety of rooftop workers. Failure to install the proper fall protection systems can lead to employee injury and may result in serious citations and fines issued by OSHA. By taking the proper precautions, you can create a safe rooftop working environment for your employees. Below is a look at the incidence of roof holes and the most effective steps you can take to prevent employees from falling into them.

How does OSHA define a roof hole?

In order to establish effective fall protection systems, it’s helpful to understand how OSHA defines a roof hole. In particular, it is important to be able to distinguish between a roof hole and an unprotected side or edge. The primary difference OSHA defines the terms as follows:

Hole means a gap or void 2 inches (5.1 cm) or more in its least dimension, in a floor, roof, or other walking/working surface.”

“Unprotected sides and edges means any side or edge (except at entrances to points of access) of a walking/working surface, e.g. floor, roof, ramp, or runway where there is no wall or guardrail system, at least 39 inches (1.0 m) high.”

How do roof holes develop?

Roof holes have a variety of causes and create a challenge for workers who navigate rooftops on a daily basis. Regardless of the nature of the roof hole, employers have a responsibility to identify them and protect workers from falling through them. Most roof holes fall into one of the following three categories:

1) Roof Damage

Roof holes often develop as the result of weather-related damage or natural events. Some of the most common types of damage include the following:

  • Age-related damage caused by prolonged exposure to the elements
  • Damage to fascia, flashing, or shingles
  • Holes caused by falling tree limbs
  • Rooftop damage caused by flooding, tornadoes, or earthquakes

2) Skylights/Roof Hatches

Skylights bring beauty and natural light to buildings but they can be dangerous without the proper fall protection. OSHA categorizes skylights and roof hatches as roof holes, requiring them to bear the proper fall protection measures. In addition to skylights themselves, there may be holes around the installation site that can pose a threat to workers.

3) Construction

Fall risks run especially high for rooftop construction workers, who must regularly contend with rooftop holes. The most common types of holes that result from construction include the following:

  • Holes resulting from removed ventilation units
  • Unguarded metal ducts
  • Holes created for chimney construction or repair
  • Open equipment hatches when removing or delivering large equipment into the building

Download Rooftop Safety Audit GuideHow can you prevent workers from falling into roof holes?

A comprehensive approach is the key to effective roof fall protection. Worker education should be combined with fall protection systems to ensure that workers do not fall through skylights and other holes in roofs. Below are four key measures that will help prevent employees from falling as they work on rooftops.

1) Develop a first-class training program

The path to fall prevention begins with a robust training program. OSHA mandates that employers develop a training program that educates workers about ways to recognize and minimize fall hazards. Some of the topics that should be covered include the following:

  • The proper procedures for erecting and maintaining roof fall protection systems
  • The use and operation of guardrails
  • OSHA fall protection standards and how they apply to your work
  • The worker’s role in fall protection planning

Ideally, these topics should be covered during onboarding, employee orientation, and periodically throughout the worker’s participation in the project.

2) Erect guardrails

“The National Institute for Occupational Safety and Health, Division of Safety Research, Morgantown, WV conducted a project to evaluate the effectiveness of guardrail systems to prevent falls through roof and floor holes. All 45 configurations met the 200-lb OSHA requirement.”

– TG Bobick, EA McKenzie Jr, and TY Kau, National Center for Biotechnology Information

Guardrails are the single-most effective means of preventing workers from falling into roof holes. Researchers from the National Institute for Occupational Safety and Health confirmed their effectiveness when they evaluated whether commercial guardrails could withstand a 200-pound force. The study confirmed that guardrails were effective in protecting workers from falling into holes in both the floor and roof.

3) Post safety signs in highly visible areas

Posting safety signs is a simple and effective way to alert workers to the presence of roof holes. Make sure that signs are posted in a highly visible location within close proximity to the roof hole. Most importantly, make sure to adhere to the following OSHA guidelines when creating safety signage:

“All signs shall be furnished with rounded or blunt corners and shall be free from sharp edges, burrs, splinters, or other sharp projections. The ends or heads of bolts or other fastening devices shall be located in such a way that they do not constitute a hazard.”

– Occupational Health and Safety Administration 1910.145

4) Use screens to cover skylights and holes

OSHA requires that “every skylight floor opening and hole shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.” Covers and skylight screens are sometimes used in conjunction with or instead of safety railings to protect workers from falling through skylights and other roof holes. When using screens to cover holes, it is important to abide by the following OSHA guidelines for construction and mounting:

“Skylight screens shall be of such construction and mounting that they are capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen…The construction shall be of grillwork with openings not more than 4 inches long or of slatwork with openings not more than 2 inches wide with length unrestricted.”

– Occupational Health and Safety Administration 1910.21-30

The Bottom Line

Skylights and other types of roof holes pose an imminent danger for rooftop workers. However, with the proper training, guardrails, and other roof fall protection measures, you can minimize fall risks for employees. By following the steps above, you can create a safer working environment for your employees and arm them with the knowledge to play an active role in the fall protection process.

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