If somebody was walking on a construction site and saw a 2’x4’ opening in the deck with no protection around it, they would most likely know immediately that it was unsafe. Whether they did anything to fix it is a different story, but they would know that it was an inherently unsafe condition. At the very least, they would probably avoid the area unless they absolutely needed to do work there.
Not so with skylights. Workers - whether construction workers or maintenance workers - on a building’s roof see the glass or plastic covering and assume they’re safe – even to the point where some will sit directly on a skylight to take their break. This has resulted in debilitating, if not deadly, consequences in the past.
The problem is that skylights are designed to protect from things like birds, weather, and small pieces of debris picked up by the wind or dropped by birds. They are definitely NOT designed – in most cases – to handle the weight of a human being. Sitting on one of these, let alone tripping and falling onto one can, and has, resulted in workers falling through to the level below.
Fall Protection Regulations for Skylights
One of the issues with skylights is the interpretation of 29 CFR 1910.23(4) which states that:
“Every skylight opening and hole shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.”
Some argue that once the skylight has glass or plastic covering it, it is no longer an ‘opening’ or ‘hole’. This is not the case. As argued in Secretary of Labor v. Phoenix Roofing (1995) [http://www.oshrc.gov/decisions/pdf_1995/90-2148.pdf], whether or not there is a covering is irrelevant. What is relevant is the possibility that somebody could fall through. The above case actually refers to the construction standards at 29 CFR 1926.501(b)(4) where each mention of skylights are in relation to ‘holes’. Somebody could interpret, incorrectly, that once a skylight opening is covered, it ceases to be a hole.
The question then becomes, “What do we do about it?”
General Industry Solutions
There are several solutions, but the requirements between general industry and construction are different, so it is of the utmost importance that you first determine which standard applied to the type of work you are doing.
If you are performing maintenance work on a roof, you fall under the General Industry (29 CFR 1910) regulations. The standard states at 29 CFR 1910(e)(8) that:
“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. They shall also be of such construction and mounting that under ordinary loads or impacts, they will not deflect downward sufficiently to break the glass below them. 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.”
A screen that supports 200 pounds and, if set upon or impacted, does not deflect so as to break the glass of the skylight. Pretty simple. Alternatively, as mentioned earlier, a ‘fixed, standard railing’ is also allowed. To paraphrase the standards, this means a railing that is also capable of sustaining a force of 200 pounds in a downward and outward direction, has a top rail at 42” and a mid-rail halfway between the surface and top rail [29 CFR 1910.23(e)(1) and (e)(3)].
What about Netting and Burglar Bars?
Sometimes people assume that netting or burglar bars can be considered legitimate fall protection for skylights. This is not the case! The problem with these illegitimate methods is that they do not protect the people who may be working underneath the skylight. This is a legitimate concern, as skylights are often used to supplement electrical lighting in warehouses and assembly areas. Falling debris could pose a significant hazard to those working below. In general industry skylight fall protection must protect the worker from falling as well as the integrity of the skylight.
Construction Industry Solutions
Construction, as always, tends to be a little more complicated, however, if you are familiar with standard construction fall protection regulations, then it’s easy to apply those to this situation. The regulations are basically the same, except that in the construction industry the glass breakage rule does not apply. If a fall through the skylight would be to a surface greater than 6’ away, the employee must be protected utilizing either a personal fall arrest system, a cover, or a guardrail system [29 CFR 1926.501(b)(4)(i)]. Keep in mind, however, that you must calculate fall distance to know if a Personal Fall Arrest system is applicable.
Even where the drop is not 6’ or greater, the employee must be protected from tripping or stepping into a skylight by covers being placed on the openings (and remember, this does not necessarily mean there is an empty void, it could mean there is glass or plastic incapable of withstanding the weight of a worker, equipment, material, or any combination thereof) [29 CFR 1926.501(b)(4)(ii)]. Those same covers would also be necessary to protect workers below a skylight from falling objects.
Skylight Fall Hazards
In the end, a skylight is a fall hazard like any other. If a worker could fall through or step through it, it must be protected. Survey your roofs and know where your hazards are. Determine the proper protection and install it before further maintenance work is done up there. As a construction company, plan what you will do when you have to work around skylights just as you would plan your fall protection in any other stage of your project. And remember, skylights could be even more dangerous than other fall hazards because of the false sense of security the glass or plastic provides. Do not take chances with your employees’ lives. Educate them on this hazard and give them the means to protect themselves.