Recently, we posted an article on the common hazards found during rooftop HVAC work. In it, we stated, “Routes of travel that take you past skylights or near the edge of the roof have now exposed you to fall hazards.” This is not an empty warning. Skylights are a hazard often overlooked during rooftop work, especially in the planning phase. If they’re thought about at all, it’s usually when a worker is already on the roof trying to figure out how they can possibly stay away from them. It doesn’t take more than a cursory search on the internet to come up with a recent article in which a worker lost his life from a fall through a skylight.
In this particular instance, a 39 year-old HVAC worker lost his life after falling through an unprotected skylight. He had been attempting to free a saw blade that was stuck in the metal decking when he lost his balance. The fall was 15’ to the concrete pad below.
There are a number of things to take away from this tragedy:
- Age, Health, and Physical Condition often mean nothing when it comes to a fall. 39-years-old. Sure, if somebody fell and survived, a fit, healthier person might recover more quickly, but falls often don’t get that far. The sheer force on the body or a blow to the head can cause death or irreparable damage on impact. In this case, irreparable damage was caused and this young man later succumbed to the injuries he sustained.
- “I have good balance,” means nothing. I’ve heard this before: “I’m not going to fall, I have good balance.” Unfortunately, just about everybody who has ever died in a fall felt that way. I guarantee you, very few – if any – thought, “Hey, I’m going to die. Well, time to get to work.” It doesn’t take much. Just this past winter a building owner was blown off the edge of the roof after he went up there to check on damage after a storm. You could have a bout of low or high blood sugar. Or you could simply stand up too quickly and get a “head rush.” The point is, in the world of safety we have to plan for the unexpected and even the unlikely.
- A properly protected skylight is as rare as a Sumatran Rhinoceros. Okay, that’s a bit of an exaggeration, but not by far. The vast majority of skylights you will encounter are either completely unprotected or are protected by a cage that would do nothing but accompany you on your fall. These cages are often in place to protect the skylight from damage, not support a falling human being. Be aware of this, because a false sense of security can be more dangerous than no protection at all.
- It doesn’t take a huge fall. Yes, 15’ is not an insignificant distance, but it may not be a distance people would automatically associate with a death. The truth of the matter is, you could fall less than 6’ feet and die if you fell the right way, so it shouldn’t come as a surprise to anyone that 15’ proved fatal in this case. Generally, there is no safe height to work at. If you fall, an injury – at the very least – is almost guaranteed.
Without a doubt, the workers in question went on the roof that day expecting to do some work, finish the job, and go home. For one young man, that was definitely not the case. What’s worse is that through the investigation, OSHA determined it was appropriate to issue the contractor a willful citation – meaning they knew about the hazard and failed to protect their employees. This incident was preventable – this death was preventable. Don’t overlook skylights as a hazard that could cost one of your employees their life.
There are many rooftop anchors on the market, however, a number of them require you to penetrate the roof membrane in order to fasten the anchor to the structure. That’s fine if the building owner allows it, but in a commercial application that is unlikely unless you are installing a permanent anchor point. For something temporary, there is no way the owner is going to want you to compromise the integrity of the membrane. So, what options do you have?
Non-penetrating roof anchors do exist. From weighted anchor points, to parapet clamps, to roofing carts, there are options. There are, of course, some things to consider before purchasing one, though:
Keep in mind that just because the method of securing the anchor does not involve roof membrane penetration, it does not mean that you won’t damage the roof. Weighted anchors, for instance, are going to be heavy so they do have the potential to cause damage once assembled or if components are dropped during assembly/disassembly. Take the utmost care in placing them and be sure you follow any manufacturer’s recommendations for protecting your roof during use. A fall protection cart can also be used and will most likely not cause any damage unless a fall occurs, in which case many of these carts are going to dig into the roof membrane, as designed. In this instance, I think patching a roof will be an acceptable alternative to having a fatality. Even parapet clamp anchors can cause damage to your flashing, especially if used in a fall, so be sure to inspect the roof when you are finished.
Arrest vs Restraint
Understand the difference between fall arrest and fall restraint, and know which your anchor is designed for. It very well could be that it’s designed for both, but you need to know how many it can support for each and if there is a different connection. Fall restraint is preventing your workers from actually reaching the edge and falling over. For this, they would need a fixed length lanyard or an SRL that – fully extended – was shorter than the distance from the anchor to the edge of the roof. Fall arrest is stopping a fall after it occurs. Anchors can be designed for either one of these or both. For instance, some roofing carts are designed for three people: up to 2 for fall arrest and the rest for fall restraint. In addition to there being a limit on the number of users for each type of protection, there are also often separate attachment points for each. It is imperative that you follow the manufacturer’s requirements if you want the anchor to protect your workers in the event of an actual fall.
Number of Users
In the example above, the cart is designed to hold three people. You cannot opt to add additional personnel to this just because there’s room for another hook. Remember, anchor points are required to support 5000 lbs. per person attached (or a safety factor of 2), so if you continue to add users and multiple people fall, the entire cart system or anchor point can fail, sending all of the attached personnel plummeting to the ground. Before you buy, know how many people you are going to need attached at once. Some anchors are designed for one. That may be fine for you. Understand that, because of swing hazards, you are not necessarily going to be able to use one anchor for work in multiple locations without having to move it. So having something portable is great. However, if you need workers in different locations working at the same time, you may require multiple anchor points.
Like every other piece of safety equipment, you can’t purchase anything without first planning what you’re going to need that equipment for. Look at the situations you expect to be in, look at the number of employees you need to protect, and look at the distance they’ll need to be working from each other. Most importantly, once you’ve purchased the equipment, train your employees on its proper use. Buying an anchor does you no good if your employees overload it or tie off to it the wrong way because they had no idea how to use it. Fall protection solutions are not one size fits all so make sure you’re speaking with the manufacturer, distributor, or a safety consultant if you aren’t sure what you need. Don’t leave the lives of your employees to chance.
We’ve spoken often in this blog about general rooftop safety hazards and regulations. We recently focused specifically on one rooftop activity when we posted about the hazards associated with washing roofs, and we felt that rooftop HVAC work deserved the same treatment. How can we best keep our HVAC workers safe when servicing rooftop units?
I know I probably haven’t, but I feel I’ve seen it all. From tools being thrown to or from a roof, to a person standing on a parapet while hauling up tools and material on a rope, rooftop workers often put themselves at risk when getting the tools and materials they need. Sometimes, this comes with the nature of the job. A quick service or maintenance visit can mean that HVAC workers are up and down from the roof quicker than you might have even realized they were there, but that doesn’t mean they can’t get hurt or killed in that short period. As an employer, the best way to avoid this is to ensure you have planned out how everything will get there in the first place. Do not leave it to the workers in the field because the moment they are faced with doing something wrong or doing something quickly, quickly often wins out.
Freight elevators are, of course, the easiest solution when there happens to be one because there is no setup involved so it doesn’t matter how long or short your work is going to be. Unfortunately, more often than not they are not available. So, what other ways can you safely get materials to and from the roof? Do you have a rough terrain forklift on site that can reach the roof? If not, does the property owner? Do you have a crane coming out to set equipment? If so, maybe you can utilize them to get tools and materials up. If you don’t have anything of great size to raise to the roof, maybe it’s a matter of simply ensuring your workers have tool belts so that their hands aren’t full when they’re climbing ladders. If all else fails, a material hoist is always an option. They are often quick and easy to set up, but be careful, you will need fall protection – whether personal fall arrest, railings, travel restraint or some other solution - while setting up the hoist and operating it since it will be at the edge of the roof (unless it is set up at a parapet that is high enough to serve as fall protection).
Routes of Travel - Slips, Trips, and Falls
Sometimes your work is in a completely safe, easily accessible place. Sometimes it’s not. Sometimes you have more than one location to work on the roof and traveling between them is where your hazards come into play. Routes of travel that take you past skylights or near the edge of the roof have now exposed you to fall hazards. Ensure, prior to beginning work, that you are familiar with the layout of the roof and that you have planned safe travel routes. This may require portable railings or other means of fall protection. Do not assume a cage over a skylight will protect you as many are not designed to serve as fall protection as you can read in our previous posts on skylight safety.
But falls aren’t the only problem when traveling on the route. Slips and trips can also be a problem as a roof can have many uneven or slippery surfaces (morning dew anyone?). Keeping an eye out where you walk or sticking to designated walkways that a building owner has established are the best ways to keep safe. Carrying material or equipment that block your vision could very well keep you from noticing that low run of conduit in your path, or that bubble in the roof membrane. Be vigilant.
You’re working on HVAC so we’re going to assume you’re very familiar with a building’s exhaust. Sometimes exhaust is a nuisance, but sometimes it’s downright hazardous. Sure, we can deal with getting covered in the smell of cooking grease wafting up from a kitchen, but what might you be inhaling if you’re on the roof of a pharmaceutical manufacturer or chemical manufacturer? Ensure that you are fully aware of a facility’s roof work policies. Do not attempt to bypass them in any way, even because you just forgot a tool on the roof, because those policies exist for a reason. Some process plants can exhaust chemicals that can make you sick – or worse - immediately.
As with exhaust, there are many other rooftop hazards that don’t involve falls. Electrical and mechanical hazards are some of them. In order to work on existing equipment, it should be de-energized and locked out in accordance with your company’s lockout/tagout program. Again, this is something that should never be bypassed, not even if you just have some quick work to do. If you can be harmed by the accidental startup of that equipment, regardless of how likely or unlikely that startup is, you must lock and tag it out in order to protect yourself. If you don’t have a lockout/tagout program or are unfamiliar with the term, you are missing some critical training and procedures in order to work safely and be compliant with the law.
You are working on somebody else’s roof, you should respect that. Small things you do could cause damage to the roof membrane which can lead to leaks and bigger headaches for the building owner. Be careful you don’t overload any one spot with materials. Don’t wear or drop anything that could cut the membrane. While keeping yourself safe is a top priority, you also don’t want to cause a problem that’s going to affect somebody else’s health or safety down the road.
Regardless of the length of time you will be on a roof, your employees must be protected. However, putting protection in place may not be enough. It is up to you to ensure that employees are properly trained to recognize, abate, or avoid hazards so they can get up, get the job done, and get down without incident. Plan ahead. It’s the best way to keep your workers safe.
Rooftop fall protection seems to consistently be one of the most confusing regulations. When warning lines and monitors can be used to determining the width of your roof, something always seems to be missed – or at least misinterpreted. So, here’s a quick and easy by-the-numbers guide for distances that come into play when discussing rooftop safety. Keep in mind, this refers to work on low-slope and flat roofs (except where otherwise indicated).
Elevation Change: Any break in elevation 19” or greater, OSHA requires a step or ladder to be provided. This is typically monitored carefully inside the average workplace, but rarely followed on the roof. Take a look at any changes in roof elevation that you have. Is there safe access to that elevation that does not require someone to step up/down 19” or more? Also, look at any obstacles on your roof. Are employees required to climb over them? This may constitute a step greater than 19” as well. These changes in elevation can be solved with stairs, ladders, and crossover platforms. We recommend using stairs wherever feasible, as this typically provides the safest access for the worker.
Fall distance: In general industry, any fall hazard 4’ or greater, requires protection. Period. Unlike the construction code, there are no exemptions to this rule.
Edge distance for roofing work: Six feet is the minimum distance from the edge of the roof, or from a hole in the roof, at which you must erect a warning line during roofing work (if a warning line is your fall protection of choice). Remember, a safety monitor, whose job it is to do nothing but ensure your personnel are not coming too close to the warning line, MUST be used in conjunction with a warning line. Six feet is only allowable in situations where no mechanical equipment is being operated or parallel to the travel of mechanical equipment when it is in use. Let me reiterate: this solution is only allowable to those on a roof for the purposes of performing roofing work. This does not apply to, HVAC repairmen and installers, security camera or satellite dish installers, or any other types of work being performed.
Controlled Access Zone: In addition, six feet is also the minimum distance for control lines used in Controlled Access Zones for leading edge work and precast work. The maximum distances vary and are listed later in this article.
Fall Distance: When performing construction work, any fall hazard 6’ or higher requires fall protection. There are a couple of exceptions to this rule that are covered later in this article.
Edge Distance for Mechanical Equipment: Ten feet is the minimum distance of a warning line from the edge of the roof, perpendicular to the travel of mechanical equipment. This refers specifically to the edge you are driving towards, not alongside. All of the same rules for warning lines as stated above still apply.
Edge Distance for Overhand Bricklaying: 10’ is also the minimum distance from the edge for a control line when engaged in overhand bricklaying operations.
Edge Distance for Non-roofing Activities: You won’t find this number in the regulations, but you will find it in Letters of Interpretation . Fifteen feet is the point at which OSHA will consider the use of a warning line for work other than roofing work as a de minimis condition, meaning that the spirit of the law was followed, just not the letter. De minimis conditions do not include any fines or requirement to change.
Maximum Edge Distance for Overhand Bricklaying: 15’ is also the maximum distance from the edge for a control line when performing overhand bricklaying.
Maximum Edge Distance for Leading Edge Work: Twenty-five feet is the maximum distance a control line can be from the edge during leading edge work. A leading edge is essentially an unprotected edge that is “moving” as the building is being constructed. For example, as a roof it being constructed, each new piece of roof decking that is installed becomes the new edge.
Roof Width: During roofing work, if your roof is no more than 50 feet in width, you may utilize a safety monitor without a warning line. This is the only situation in which this configuration is acceptable. If you are having trouble determining the width of your roof, you can refer to Appendix A to Subpart M of the Construction Regulations for guidance. Keep in mind, this only applies to roofing work.
Maximum Edge Distance for Precast Concrete. 60’ (or half the length of the member) is the maximum distance a control line can be from the edge when erecting precast concrete members.
Okay, that’s a little cheating on my part. It’s not technically a number, but it represents the distance OSHA feels you can work from the edge of a roof safely without the need for fall protection. That’s right, there is no distance OSHA deems as a safe distance from a roof edge, so technically you should be protected at all times. With that said, in numerous letters of interpretation, OSHA does view 50’-100’ as a potentially safe distance with the proper work rules and training in place. Be very careful using leveraging this as an excuse out of protecting a hazard. The concern here is that OSHA wants a distracted worker (the worker at highest risk) to be protected. If a worker is distracted, distance alone will not necessarily wake them up to their surroundings. A railing or warning line would.
Hopefully, this list can be used as a quick-reference guide for those readers involved in rooftop work. Remember that not all trades and tasks are created equal on a roof. Do not assume what is good for one group of employees or contractors is good for another. Keep your numbers straight and keep your employees safe.
I recently had the opportunity to cross our southern border and experience Hispanic culture first hand. I didn’t go to a resort or a hotel on some beach. I went to stay with some dear Mexican friends who live in the mountains of Veracruz. An unintended consequence of the trip was a view into the immigration dilemma from their side of the border. While enjoying incredible hospitality, great food, and hardworking passionate people, I also saw crushing poverty. Making an average of $60-$80/month, the locals have little hope of ever buying many of the staple comforts we enjoy in America. For many Mexicans, owning land, a vehicle, a refrigerator, TV, etc., are all distant dreams. Dreams, that is, unless they decide to make the journey to the land of opportunity. Unfortunately, many of these journeys are made illegally.
I know what you are thinking…Here comes another person publicly asserting their view of the immigration crisis. On the contrary. Although I have come to love the people of Latin America, I do not profess to know how to solve this problem. Each person's beliefs and experiences provide a range of perspectives. These perspectives express a real sense of fear, injustice, inequity, or hope.
What I aim to bring into the spotlight is not immigration reform. I want to draw our attention to some of the workplace difficulties that immigrants face when reaching America. Since we are a safety company that is where I will focus.
The good news first. America experienced a 2% increase in workplace fatalities from 2013 to 2014 (not the good news). Latino workers, yet, experienced a 3.4% decrease.
With that said, more Latino workers died in 2014 than 2009, 2010, 2011, and 2012 respectively. Additionally, a disproportionate number of foreign-born Latinos lost their lives. With the foreign-born population comprising only 35% of the total US Latino population, they accounted for 67% of the fatalities. Foreign-born Latinos are almost twice as likely to die at work than US-born Latinos.
A recent study performed by “Make the Road New York”, a Latino advocacy group, interviewed a number of immigrant workers and small business owners. They found that nearly all workers interviewed believed they had worked in unsafe working conditions. They also found that half had been injured on the job and half did not know OSHA existed. Many of those interviewed also expressed a fear of retaliation or a belief that it is futile to make their safety complaints known.
Additionally, many Latinos find work in the construction and agricultural sectors. These sectors have abnormally high fatality rates. OSHA recently released a report that compares the number of hours worked against the number of deaths that occur in that industry. The result may not surprise you. When compared to the national average, workers in construction were almost 3 times more likely to suffer a fatal injury. Workers in agriculture were 5-6 times more likely.
While it is not possible to change what types of jobs immigrant workers are accepting, it is possible for them to have a safer place to work. For starters, let’s talk about what rights workers are afforded in the US under the OSH Act.
OSHA provides employees with the right to:
1. Have a safe place to work
2. Information (about hazards, past reporting, etc…)
3. Training (how to work safely)
4. Report hazards
5. Be safe and free from retaliation
These rights are provided to workers – without regard to their immigration status. Illegal immigrants are provided the same rights as legal immigrants. In fact, some states even provide workers compensation for injuries on the jobsite… again, without regard to immigration status.
In OSHA’s eyes, it does not matter how you arrived in the US – legal immigrants, illegal immigrants, and natural citizens are all covered by this Act.
The challenges around this issue can be complicated especially when the worker is here illegally. They include:
1. Awareness of rights. As I already mentioned, many Latinos who were interviewed do not know OSHA exists.
2. Education of hazards. Dangerous work is a part of life for many Latinos – both in their home country and here.
Education of immediate hazards may be an obvious place to start, but many are also not aware of hazards that could pose long-term health issues.
3. Confidence that there won’t be retaliation.
Back to the story of my trip to Mexico. Here is where I want to make a special plea to employers. I lived with a few of these men who had made the trip into the US. I do not condone the breaking of the law, but I understand why they would do it. Few of us wouldn't if in their shoes. If you are in a position to bless those who have left their land in search for a better life, do so.
When they return to their families, make sure it is with their health intact. Afford to them the same safety and security that you would want. Protect their rights as sojourners in our land.
I know that I am bringing up a topic that has many passionate supporters on both sides. What I hope for, though, is to find a common desire to have our workplaces safe for the dads, moms, sons, and daughters that work there. I think we can all agree on that.
How would you attempt to address this issue? What additional challenges do you see?