In the last article, we discussed the first level of control when it comes to protecting employees from recognized hazards: elimination or substitution. The concept, while possibly difficult to implement, was simple to understand. Unfortunately, this second step, engineering controls, is often more difficult in both concept and implementation. (Note: there seem to be two schools of thought on this hierarchy or controls. One is that substitution and elimination fall under engineering controls and the other is that they are separate. For the purpose of this article series, we’ve chosen to separate them into different categories.)
Engineering controls, to put it as succinctly as possible, are methods designed to get as close to eliminating the hazard as possible, without actually eliminating it. This is done by designing something into the facility, the piece of equipment, or the procedures themselves to reduce the hazard or the employee’s exposure to it. As long as they are designed properly (and used by employees properly) they tend to be very reliable.
An example of an engineering control is isolating a hazardous portion of the process. In manufacturing, for instance, a part of the process may be spray painting parts. This task poses both health and ignition concerns. In order to isolate the hazard, many manufacturers would utilize a spray booth. The booth prevents the worker from inhaling the paint fumes and paint residue while also reducing the risk of explosions and fires. A glove box for handling hazardous materials and chemicals is another example of isolation as the box allows the employee to do the work while not being exposed to the material/chemical.
A process change is also considered an engineering control. This control is common (though maybe not common enough) when dealing with silica. Using water to suppress concrete dust or a HEPA-filtered vacuum attachment to remove the dust from the air are not only good controls, they are – in ways – integrated right into the new silica standard. Automating the hazardous work so that no employee has to be exposed is another example of a change in process.
Another option is ventilation, the most effective of which is local exhaust. Local exhaust removes the hazard (in this case, a fume, gas, vapor, or dust) at its source, while general ventilation allows the hazard into the work area as it’s diluted to an acceptable level or as it’s pulled or pushed (depending on whether it’s a positive or negative pressure system) into an exhaust duct, door or window. Dilution methods are really only able to be used in very low toxicity situations where employees are able to maintain a safe distance from the source. General ventilation can be costly as large amounts of air need to be moved in larger spaces and that air often needs to be temperature controlled to keep the workplace comfortable.
Often, an engineering control doesn’t exist in a vacuum. Some need to be used in conjunction with other controls, such as personal protective equipment, to ensure they are used and working properly. Training is always required because no system is human-proof. In fact, engineering controls are definitely not a one-size-fits-all solution. Before one is selected, it’s necessary to look at a number of factors. How easy is it to use? Your employees are going to be expected to use it properly. An over-complicated system could greatly increase the possibility of human error or, worse yet, the possibility that your employees choose to attempt to bypass the system. How reliable is it? Engineering controls need to have a practically perfect rate of success. If they don’t, not only are your employees not protected, but they may be operating under a false sense of security. How much does it cost? Yes, as safety professionals we like to think it’s “protect the employees, no matter the cost!” but in the end, employers do still exist to make a profit. That’s not to say that a company will not implement necessary controls, but they’re not going to be happy if they spend a fortune on one solution only to discover that there is a cheaper and equally effective solution available. Do your homework before selecting any one option.
Engineering controls are your best option when the hazard cannot be eliminated. Ensure the safety of your employees by selecting/designing the proper solution and then train your people so that the control works as intended. If the possibility of substitution, elimination, or engineering controls all fail – or if you simply as desire additional protection – administrative controls will be the next step.
We’ve covered many different types of fall protection systems and their components in this blog, but somewhere along the line, you may have heard the terms “active” and “passive” fall protection systems. Are you aware of what they mean?
A Passive System is much like it sounds – working whether you do something to it or not. A passive system is something that is in place, has no active mechanisms or moving parts, and requires no human interaction in order to function properly once installed. These tend to be your guardrails and netting.
Whether you are “using” a rail or not, it still stands, ready to do its job. Whether you fall into a net or not, it is still there. There is nothing for you to do in order to get them to work. There are no moving parts that are required to be used in order for it to save your life.
Active Systems, like Passive Systems, are just like they sound. They are dynamic. There are mechanisms at work that are protecting your employees’ lives. These systems tend to be your fall arrest and travel restraint systems. These systems involve a harness, some type of lanyard, and an anchor point (and, in the case of fall arrest, the need for a rescue plan). In order for these to work, your employees need to inspect and don equipment, adjust it, tie-off to an anchor point, and make sure they are using the equipment properly. If they fail to perform any of those steps properly, the fall protection may not work as intended.
Active systems tend to be used in lower traffic areas in which passive systems cannot be feasibly installed or that are constantly changing (such as in a construction setting) making something like a railing difficult.
Fall Prevention vs Fall Arrest
Don’t confuse active vs. passive with fall prevention vs. fall arrest. At first glance, it might seem that passive protection is the same as fall prevention and that active prevention is the same as fall arrest, but that doesn’t hold true. While rails (passive) are fall prevention, a net (passive) is fall arrest. While a PFAS comprised of a harness, shock-absorbing lanyard, anchor point (active) is fall arrest, a travel restraint system (active) is fall prevention.
Understanding the industry terminology goes a long way in helping sift through the “noise” of regulations, requirements, policies, and information you are going to have to deal with. Don’t ever assume you know what new terminology means. Seek out what you need to know. Often, a quick search on the internet will give you the full answer (as long as you’re using a reliable source). In other words, be active in increasing your industry knowledge and understanding, not passive!
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.
The recent accident in Westwood, MA regarding the fall of a worker clearing snow from the roof of a business, underscores just how dangerous this job can be. In this particular instance, the worker fell through a skylight and landed on the ground 25’ below. In light of the situation, OSHA has issued an advisory on snow removal urging people to review the OSHA Hazard Alert Documentation.
Roof work is dangerous enough when all of your hazards are visible, but poorly protected fall hazards blanketed in snow are a recipe for disaster. Had this skylight been properly protected, this worker would not have been able to fall, but that doesn’t mean there aren’t other dangers. In the past, OSHA has responded to incidents regarding workers falling through tarp covered elevator shafts or even just sliding down a sloped roof. This is why it’s imperative to come up with safe solutions for snow clearing.
Is It Necessary?
This is the first question you need to ask yourself and, undoubtedly, in many situations the answer is yes, it is necessary. Reasons usually range from emergency roof repair and maintenance to the prevention of overloading and collapse. If it is not necessary, wait, but if it is, then find the best way to do it.
Is It Necessary To Go ON The Roof?
There are many ways to perform snow clearing. Shoveling from the roof itself might be the most dangerous. If your concern is that the roof might become overloaded, how is adding the weight of workers and equipment going to help that? Depending on the type of building you have, you may be able to utilize a snow rake. These long-handled devices give the user the opportunity to clear a roof from the ground or from an aerial lift. These rakes should NOT be used while standing on a ladder. The movement and length of the rake could cause you to lose your balance. As always, with any long-handled tool, be aware of surrounding electrical hazards and stay the necessary distance away.
If It IS Necessary, What Fall Hazards Might Be Encountered?
No worker should ever enter any situation blindly. Prior to accessing a roof, they should be fully aware of what hazards they might encounter. Are there skylights? If so, are they protected? Is the roof flat or sloped? Is there a parapet high enough to act as fall protection? What is the load capacity of the roof and how close to exceeding it are you? Workers should remain off the roof until these questions are answered. Once on the roof, they should clear off the roof uniformly, and avoid making snow piles on the roof to prevent overloading.
What Needs To Be Done To Protect The Workers?
Simple. There are no fewer requirements for fall protection during snow removal than during any other type of rooftop work: fall arrest systems, fall protection carts, railings, whatever it takes. Emergency situations do not give companies the right to forego regulatory compliance. In fact, emergency situations probably need closer attention to safety because of their nature: everyone is working quickly to rectify the situation. It’s understandable that if there is a concern that a roof is going to collapse that the work needs to be done quickly, but it should never be at the cost of a worker’s life.
In addition, some simple planning could prevent injury and death later on. Ensuring that fall hazards are properly protected before the snow comes is critical. If a snowstorm is coming, perhaps going to the roof before it arrives to mark potential trip hazards will be of great benefit after the storm.
- Roof Access: If ladders are the way to go, then make sure they are inspected and set up properly, the rungs are clean, and you avoid any electrical hazards.
- Slips, Trips and Falls: Clear off the bottom of your boots to ensure that you get the best grip possible on ladder rungs. Also, remember that ice can be hiding underneath the snow. Walk slowly and deliberately to avoid slipping.
- Equipment: If using an aerial lift to perform the work, ensure that the operator is properly trained and qualified.
- Exposure to Cold: Train your workers on hypothermia and frostbite. Ensure that they are aware of the signs and symptoms, as well as what to do should they suspect either is occurring.
- Back Strains: Shoveling can lead to back muscle issues. In order to avoid this, ensure that workers are using ergonomically designed shovels, are scooping or pushing smaller amounts of snow, are using proper lifting techniques.
- Dehydration: People tend to forget that hard work in cold temperatures can lead to dehydration just as it does in high temperatures. Take frequent breaks and drink fluids (avoiding caffeine and, of course, alcohol).
Be prepared as you would for any other weather event. Know what your plan is and work that plan. Do not take shortcuts with the well-being of your employees.
New York City is in the middle of a huge underground excavation project that has been going on for years. The pictures from the subterranean world are dramatic and have found their way onto websites and news magazines around the world. As a safety professional, you can't help but notice the massive usage of guardrail in the project. That being said, you probably also can't help but notice how unsafe it is!
The picture above is a great example. The railing system pictured is meant to be used on flat surfaces with specific "returns" that keep the system counterbalanced. Certainly they serve as a "warning" that there is an edge there, but beyond that I'm not sure that they would come close to stopping a fall or meeting the OSHA top rail loading requirements.
This is the kind of "lip service" to safety that can become deadly on a job site. Certainly it appears that there is a railing there, but the reality is, it's still probably very unsafe and would not prevent a fall if someone where to back into the system.
Safety equipment that is not used according to manufacture's specifications is no longer safety equipment! Rather it is an accident waiting to happen. Be sure to follow safety equipment instructions or else you may be creating a deceptive hazard instead of providing safety for the worker.
Below is a comprehensive list of safety railing solutions that are available to our customers. Not every safety railing solution is a fit for every environment, so we've called attention to where each railing works best. All of these safety railing solutions are OSHA compliant unless otherwise noted.
Environments: Flat Roofs or Low Slope Roofs
KeeGuard is a non-penetrating guardrail that uses counterbalanced or post weights to keep the railing firmly anchored on the roof.
Environments: Standing Seam or Corrugated Metal Roofs
KeeGuard metal roof can be attached to standing seam roofs with non-penetrating S-5! clamps. The railing attaches to corrugated metal roofs with a special plate that must be screwed into the roof surface.
Environments: Flat Roofs and Job Sites with Flat Surfaces
Portable guardrail can be used as a permanent solution or a temporary guardrail that can be moved from location to location. Portable guardrail has 5'-10' sections of railing that are held up by weighted bases.
Environments: Roofs with Structural Parapets
This railing can be attached to existing roof parapets to provide a guardrail that meets OSHA requirements.
Environments: Flat and Sloped Surface (ground or wall) that can receive a fastener.
This is a very flexible option when it comes to creating guardrail and safety railing. It can attach to virtually any surface and provides barrier protection that is OSHA compliant.
Environments: Flat Surface (ground) that can receive a fastener.
This railing kit can be purchased in three kits: corner, straight and extension. It is galvanized and then powder coated safety yellow. It comes partially assembled in the box and is very simple to complete the assembly.
Environments: Construction Site
There are various types of railings that attach to many different kinds of surfaces. Most of the railings in this category are designed to be temporary and meet OSHA standards for guardrail.
Environments: Ramps, Stairs and Flat Areas that Require Handicap Access
ADA railing can be designed to provide OSHA fall protection, but the default configuration for ADA railing only takes into consideration handicap access laws.
Environments: Around Roof Hatches
OSHA compliant railing that attaches to a roof hatch. This railing also provides a grab point for people entering and exiting the hatch.
Environments: Around Skylights
OSHA considers a skylight to be a hole in your roof. Skylights must be protected with the appropriate railing. KeeDome is a non-penetrating railing that hugs the edge of dome skylights.
In order for a roof parapet to provide adequate fall protection, a roof parapet should be at least 42" in height. Unfortunately, many buildings get close to this height without quite meeting the height required by OSHA to provide fall protection. There are several solutions to help you raise the height of your parapet that are cost-effective and aesthetically pleasing.
Here are several solutions if you find yourself in a situation where your parapet does not meet the fall protection height requirement.
1. Raise the Parapet Height with a Railing
This is the simplest solution. If you can penetrate your roof parapet, there are several roof parapet railing solutions. We offer railings that attach to the top of the parapet or the outside of the building. Find our more about these types of railings on our roof parapet railing page.
2. Install a Non-Penetrating Full-Height Railing
If penetrating the outside of the wall is not an option, a freestanding, non-penetrating railing can be used to keep people back to from the roof edge. Find out more about KeeGuard, our non-penetrating roof railing.
3. Use Temporary Parapet Railing Clamps to Build a Railing
If you only require temporary access to a roof with a lower parapet, then parapet clamps are a cost-effective option. The clamps are designed to clamp onto the roof parapet. The railing is then formed by inserting 2x4s between the clamps to form a safe, temporary barrier. Click here to find out more about temporary parapet railing brackets.
Whatever the situation you find yourself in, reach out to our trained sales staff. They can recommend products and help you understand the benefits of the different parapet railing solutions that are available.
There is a new generation of railing that is emerging from Kee Safety: Kee Lite Smooth Aluminum Railing. As it's name indicates, there is now a way to build smooth aluminum railing with a modular, component based system. Kee Lite Smooth features a railing surface that is smooth to the touch. Such railing is helpful when designing and building ADA railings as well as railing for the wastewater treatment industry. Many of the features that are gained from using a fittings based system apply to the Kee Lite Smooth railing system.
Kee Lite Smooth - Ideal for the Wastewater Industry
We have always been able to provide aluminum railing systems, but those railings were standard railings built with slip-on fittings. The wastewater treatment standards call for the use of smooth railing. Kee Lite Smooth fills this niche and offers a modular, smooth aluminum railing that meets water treatment railing standards. Aluminum is corrosion resistant making it an extremely durable railing in the moisture rich environment.
Get a Project Quote
If you would like a quote for a Kee Lite Smooth railing system, begin by contacting our sales team. They can work with existing drawings or assist in the design process. Click here to contact us.
Cross posted from Simplified Building
Pallet Gates are typically found on mezzanines, but they can be used in other industrial applications. This pallet gate was used on a work platform that was built around an industrial mixing platform. The pallet gate allows for items to be lifted onto the platform (e.g. pallets of materials to be put into the mixer) while at the same time providing safe access to the people working on the platform.
These pallet gates were installed onto an existing work platform with the addition of fall protection railing. OSHA requires that general industry employees working at a height greater than four feet have adequate fall protection. Adding safety railing and pallet gates to these work platforms brought the system into compliance and provided a safer working area for employees.
Pallet gates are special safety gates that open only from the outside. This allows pallets and other items to be pushed into the working area with a fork lift. The gates do not swing in the outward direction. Pallet gates come in two standard sizes, but custom options are available. To find out more about our pallet and mezzanine gates, please visit this page: Pallet Gates
Putting a railing on a roof comes with a number of distinct issues. KeeGuard roof railing has number of benefits that will help you to address these issues.
Issue 1: Do Not Penetrate the Roof Membrane
A roof has one distinct purpose, to keep the weather out of your building. The last thing you want to do is put a hole in what is supposed to be keeping water, wind, heat and cold on the outside. Roof railing that penetrates the roof will only cause you more headaches in the long run. The solution is KeeGuard roof railing. KeeGuard uses a counter-balanced system to hold the railing in place. The result is that the railing will not penetrate the roof membrane.
Issue 2: Ensure that it is Safe / OSHA Compliant
In order for a roof railing to be effective in preventing a fall, it must be able to resist the loads as laid out in OSHA 1926. OSHA says that the top rail of the railing must be able to resist 200 lbs of point load without deflecting. KeeGuard roof railing exceeds this requirements and has the test documents to prove it. Each roof railing system is designed by a sales engineer to ensure the highest level of safety. Do not entrust your employee safety and business liability to mere claims! Get the testing data.
Issue 3: Navigating Roof Obstacles
Most roofs were not designed with railing in mind. There are often obstacles on the rooftop that make the installation of railing difficult. KeeGuard uses modular fittings and standard pipe that make it easy to navigate obstacles that are located on the rooftop. Whether it is a ventilation duct that extends over the edge of the roof or a piece of equipment that installed close to the roof edge, KeeGuard roof railing can be used to protect workers who are accessing these areas.
Issue 4: Keep the Architects Happy - Make it Look Good
Architects have an interest in making sure their design is not corrupted by the addition of a railing to the rooftop. Safety and aesthetics do not have to be mutually exclusive. KeeGuard roof railing has a number of features that make it an acceptable, good looking solution. First off, it's galvanized and not painted safety yellow. This means that the railing is less visible and blends in better with its surroundings. The railing can also be powder coated so that it blends in perfectly with the aesthetics of the building. Secondly, the roof railing can be angled away from the roof edge to make it less visible from the ground. The railing remains compliant, but has a smaller "visual footprint" when viewed from the ground. Thirdly, unlike other roof railing systems, KeeGuard has a contiguous railing. There are no breaks in the railing, making it look more pleasing and well integrated into the building environment.
Issue 5: Install Quickly and Safely
A roof railing that can be installed safely and efficiently is another must! KeeGuard's modular design makes it assemble rapidly without the use of welding or drilling. An Allen key, torque wrench, pipe vise and pipe cutter are all that is needed to install this roof railing. Special non-penetrating temporary anchor points are also available to make sure that your workers are safe while doing the installation. On top of being installed quickly and safely, Simplified Safety also offers several levels of installation services. We can come on site and help your crew install the system, or offer complete turn-key installation.
Issue 6: Must Resist Corrosion and have Long Lasting Durability
The KeeGuard roof railing system is completely galvanized. Because it is not a welded system, it is more impervious to corrosion than standard welded railing that has been painted. KeeGuard systems are built for long lasting durability. Annual maintenance will ensure that your railing last for many years. It's modular nature also ensure that any damaged parts can be easily replaced.
Whatever the issues are surrounding roof railing, KeeGuard has the solution. The KeeGuard system is the industry leading roof railing solution because it performs well in all circumstances.
Find Out More about KeeGuard Roof Railing »