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When Will the New Walking/Working Surface Rules Arrive?

DIY Bathroom Shelf

“When will the new walking/working surface rules arrive?” is a question that’s been asked for many, many, many years (as in about 20), but it finally looks like we may have an answer.  According to a regulatory agenda published by OSHA in May of this year, the Administration plans to release the final rule for Walking/Working Surfaces this month (August 2016).  The rule had been so long in the making, that it essentially needed to go back to the drawing board in order to properly account for new technologies that did not exist in earlier versions.

So what is different this time?  Well, with the rule ready to go, despite the fact that regulatory agenda dates are often missed, the administration wants to try to take advantage of the Obama presidency to get this done.  Traditionally, Democrat administrations tend to be more regulation-friendly than Republican administrations and OSHA does not want to take a chance on the Presidential Election, hence the push for a release of the final rule this month.

What’s new?  Well, mostly fall protection.  It may come as a surprise that there is very little said about fall protection in the General Industry standards.  In fact, personal fall arrest systems are not mentioned at all.  Other than physical barriers and railings, there is no fall protection guidance.  The proposed final rule aims to change that.  In addition to addressing fall protection and personal fall arrest, the new rule includes updated national consensus standards and industry practices.

The actual changes will occur in two subparts: D (Walking/Working Surfaces) and I (Personal Protective Equipment).  Subpart D changes will simply be the requirement to have fall protection, while Subpart I will go into the performance requirements of that equipment.  Don’t worry about having new things to remember.  If you’re already familiar with construction and Shipyard standards, you will recognize much of what you see as some of the same language is being pulled in order to maintain consistency and avoid confusion.

While the implementing the new rules may cost money, OSHA fully expects that company savings will outweigh costs by almost a factor of 2.  And that’s for companies that are not already implementing any aspect of this.  Many forward-thinking companies that fall under the General Industry standard may already be using the Construction or Shipyard regulations as a model for their fall protection programs.  In this case, extra costs may not exist.

Regardless, OSHA expects the rule to have a big impact.  OSHA administrator David Michaels said so himself in an interview in the July issue of the National Safety Council’s Safety and Health magazine.  Aside from financial savings, the Administration expects the new rules to prevent 30 annual fatalities.  And, in the end, that’s the ultimate goal.  Saving lives.

Why Can’t My Managers Get My Staff to Comply?

Why Can’t My Managers Get My Staff to Comply?

Sometimes you can have the best program on paper, but it doesn’t seem to be translating well to real-world implementation.  Maybe your workforce is telling you they like the program, but every time you observe them, they’re breaking the rules.  Maybe your supervisory personnel seem reluctant to enforce the program.  Whatever the breakdown, a great written policy means nothing if it’s just a dust collector on your shelf.  So, where might the breakdown be? 

Often, the breakdown does not lie with the line worker, construction crew member, maintenance staff, or other personnel whose work the policies and procedures most directly affect.  Sure, they’re breaking the rules, but they do this because somewhere along the line, this has become acceptable.  Something has shown them that they can get away with this behavior.  The real source of the problem, when it comes to implementation failure, often lies with supervisory personnel and/or company executives. 


Supervisors Don't Care to Implement the Program

Everybody needs motivation.  Some people will follow company policy without question, but others will be resistant to change.  Perhaps the idea of a safety program seems like too much work or a distraction from what they consider their “real” duties.  Others might see it as added work without a clear idea of “what’s in it for them.”  If a supervisor is unwilling to enforce your rules, then you have no chance of getting their subordinates to comply. 

In order to motivate supervisors you need to provide them with incentive.  That doesn’t necessarily mean implementing an incentive program, per se, but rather giving them ownership of the program and accountability for its successes and failures.  In order to do this, supervisors must first be made aware of why they need to implement a safety program and how important it is to the company.  This should be coming from company executives, not from a peer.  The higher up the person introducing them to the concept, the more likely they will be to follow it (as long as they see that any superiors between them and the executive are completely on-board).  Let’s say the company’s CEO stops into the plant to meet with the supervisors regarding the company’s safety performance and its need to implement a new program.  The CEO must be authentic.  If they could care less about the program, your company personnel will sniff that out right away and your program will fail before it even begins.  If they’re doing it simply to save a few bucks on insurance, the supervisors and other employees will detect those motivations immediately as well.  It's not that it’s bad to want to save money, but if it’s obvious that the new program is all about that and avoiding injury is only a lucky by-product, it will be hard to achieve any level of enthusiasm.  In other words, it needs to be true – and obvious – that the company cares about the well-being of its employees.

From the moment the program is launched, management needs to lead by example.  You can’t expect workers to wear their safety glasses and steel-toed boots 100% of the time when your VP walks the floor in tasseled dress shoes and no eye protection.  Not only is that poor leadership, but if there truly is a hazard that requires this PPE, then they are putting themselves at risk for injury.  A flying piece of debris does not care if the eye it’s about to enter belongs to a laborer or the company owner.

Instituting an incentive program for supervisors is always a good way to get buy-in, but it probably needs to be different than what you’re offering their subordinates.  Point systems for prizes or gift cards for dinners only go so far.  They build incentive, perhaps, but no accountability.  Tying a portion of a supervisor’s annual bonus, for example, to the company’s safety performance, the safety performance of their direct reports, or both, is often effective.  They can make extra money with good performance, but lose a portion for bad performance.  Be sure to use leading indicators (safety meetings held, near miss reports submitted, training completed) rather than lagging indicators (number of injuries, number of days away from work).  Using the latter can run you afoul of OSHA’s new recordkeeping rule (click here for more information).

Wrong Person for the Job

Sometimes people find themselves in supervisory positions for the wrong reasons.  Maybe they’ve lasted longer at the company than everybody else or maybe they are really good at the job being performed.  These are great things that make up part of what it takes to be a manager.  Managing takes interpersonal skills, time management skills, conflict resolution skills, and some understanding of the legal liability inherent in his or her position (among other things).  Just because a worker operates a forklift better than anybody you’ve ever seen doesn’t mean they can manage the warehouse.

If the person in charge of implementing your program lacks any of the aforementioned skills they may give up on trying to get the workforce to comply the moment they get push back.  Heck, they may not even try in the first place.  In these situations, you sometimes end up with what I call ‘the reluctant manager’.  This is the person that accepted the job (maybe for the pay raise, maybe because they were honored by the offer, maybe because they were afraid they’d be fired if they refused it) but doesn’t necessarily want the responsibility.  Sometimes, you’ve promoted from within and the supervisor is still trying to be buddies with all of the employees rather than trying to successfully manage them.  These are recipes for disaster for your program.

A reluctant manager may take the approach that they’re as annoyed as the rest of the workforce with the safety program, but it’s something they’re being required to do.  This is going to set the tone for performance.  Think about it.  How would your employees react to, “Hey guys, listen, we’ve gotta do this stupid safety thing.  I know it’s a pain in the butt, but we have to do it, so don’t give me a hard time,” versus, “Guys, the company has been reviewing our safety performance and has determined that the rate at which our employees are getting hurt is unacceptable.  Not only does it affect company performance, but guys are out on worker’s comp collecting partial pay instead of their full salary.  Employees’ lives are being affected because these injuries prevent them from doing things with families and friends that they love to do.  It’s time to turn this around with this new program and it’s my job to implement it.  I expect full cooperation.  If you have any questions or concerns, please come speak to me, but rest assured, failure to comply is not going to be tolerated”?

A manager that is trying to remain friends with the staff may not be the person for the position, however, when hiring from within the opposite situation can also be a problem.  Your manager may very well be trying his or her hardest to manage, but they are not getting the cooperation or even the respect of the workforce.  This may become painfully evident when that manager tries to implement the safety program.  Sometimes it just takes a company executive coming to speak to the workforce about the employee’s promotion: why it was needed, what this person has done to deserve it, and what their role is.  It needs to be left that in no uncertain terms this person is now their supervisor with full support of the company.  Even with all that, you can’t make them respect this person, but hopefully you can get their cooperation.  Respect will have to be earned and commanded by the manager in due course.

Manager Doesn't Know or Understand Their Responsibilities

Just as the expectations need to be set with the workforce, whether with an internally promoted manager, a new hire, or an existing manager that is just being introduced to your new safety program, you must also set their expectations.  Ensure that they know that safety is their job.  Even if you have a corporate safety director or a field safety manager, a safety program will not work if management isn’t enforcing it.  They need to understand that it is as important a job as everything else they do.  Don’t feed them a line about “safety first” because the first time you or somebody in your organization puts schedule or profit ahead of safety (and it will happen, unfortunately) they’ll really understand where safety lies among the company’s priorities.  Instead, explain to them that safety, production, and quality are all equal and that no one of those can be successful without the other two.  And mean it.  If your manager gets reamed out because he or she had to delay starting one day because some fall protection harnesses were bad and somebody had to replace them, he or she is going to know the company doesn’t value safety over schedule.  In the future, they’ll act accordingly.

If they do know what their role is, do they understand safety itself?  Maybe they’re really good with your people.  Maybe they really understand the methods and procedures you have employed until now.  But, do they know the regulations that apply to the work they’re performing to know if those methods and procedures are in compliance?  Do they have the ability to analyze a task and determine its hazards?  Do they have the ability to abate those hazards?  In other words, have they received the proper training, or have they just been told – “safety is now your job”?  Training is key.  If your managers don’t understand safety, how can they manage it?

From all this, we can see that implementing a safety program is much more difficult than grabbing some boilerplate program and telling your employees to run with it.  Everybody, top to bottom, has to be trained.  Procedures need to be customized to be applicable to the work you’re performing.  But, most importantly, your supervisors need to be on-board.  Without them giving 100% to program implementation, without them displaying the proper knowledge and attitude, without a clear-cut consistent safety message at all levels of management, your program is doomed to failure.  Get your supervisors involved and accountable and your workforce will quickly follow.

Active vs. Passive Fall Protection Systems

Active vs Passive Fall Protection

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?

Passive Systems

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

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!

What Does the New Recordkeeping Rule Mean to Me?

What Does the New Recordkeeping Rule Mean to Me?

By now, you may have heard: OSHA issued a new final rule in regards to electronic recordkeeping.  Great!  What the heck does that mean? 

Well, funny you should ask, because I’ve got answers!

Just the Facts

Let’s start with the basics.  The final rule was issued by OSHA on May 12, 2016 and will require certain employers to electronically submit their injury and illness data (300, 300a, and 301  forms) to the Agency annually (before these were only collected through an inspection, a survey, or when things like fatalities and hospitalizations required employers to notify OSHA).
Those required will be:

  • Companies with 250* or more employees who are otherwise already required to keep these records.
  • Companies with 20 to 249* employees in “certain industries”.  This is primarily industries OSHA deems highly hazardous such as utilities, construction, manufacturing, retail, transportation, and health care.
  • Other companies upon OSHA request.

*When determining your number of employees, you must include part time, seasonal, and temporary workers.

These requirements will phase-in beginning in July 2017 and will be fully implemented by March 2019.

In addition, the new rule includes new protections for employees against retaliation and will require OSHA to scrutinize incentive programs and post-accident drug/alcohol screening to ensure they don’t discourage reporting of illness and injuries.

In terms of anti-retaliation measures, employers must notify employees that they have a right to report work-related injuries and illnesses, that they will not be discharge or discriminate against for reporting them, and the employer is prohibited by law from discharging or discriminating against somebody for reporting a work-related illness or injury (effective August 16, 2016.  While OSHA has had this in their purview for some time, the new rule allows OSHA to bring action even without an employee complaint of retaliation, which was previously required in order to begin an investigation).

As for discouraging employees to report, incentive programs must not punish an employee in any way for reporting an injury/illness.  For example, if a monthly safety bonus is given, and an employee is not eligible if they have an OSHA recordable incident, OSHA may consider this retaliatory and/or a means to discourage an employee from reporting their illness or injury.  In addition, blanket post-incident drug/alcohol testing will not be possible.  While OSHA will still allow “for cause” testing and testing mandated by a government agency (i.e. – the DOT), the company is going to have to show that requiring drug/alcohol testing in any other instance was reasonable.  For instance, if somebody gets a splinter that gets infected, they may not consider testing reasonable while if an employee swerved and crashed a company vehicle, they may.

What are the Consequences?

One major concern is that the reason many companies instituted blanket post-incident drug/alcohol testing was to eliminate any possibility of a false discrimination claim.  The prohibition of this type of policy seems to open that back up.  In addition, the National Law Review cited four consequences of this rule in a recent article they published.  To paraphrase:

1 – Information will be used to identify new bad actors.  Those reporting higher than normal injury and illness rates can expect their chances of inspection to dramatically increase.

2 – Electronic submission opens the door for data breaches and hackers.  Personal information of injured employees could be vulnerable prior to the agency scrubbing that information from the files.

3 – This information will be made public, so companies could be negatively affected by this before they have a chance to defend themselves.

4 – The information will be made public, so may be used as a tool for unions to find companies whose workforce may be more interested in unionization.

5 – It’s a new weapon OSHA didn’t have before – the ability to cite any company reporting policy/procedure for being “unreasonable”.

This is now the law and, while it will take some time to fully implement, you can begin notifying and training your employees now.  In addition, it’s probably time to review your incentive programs and drug/alcohol testing policies.  Don’t let this catch you off guard.  You know it’s coming, so make sure you don’t leave your company vulnerable to non-compliance.

Click here for more OSHA information.

What Are the Different Types of OSHA Violations

What Are the Different Types of Osha Violations

We often focus here on what you need to do to keep your employees safe and to ensure your company is compliant with the law, but at some point in time, some of you are going to be involved in an OSHA inspection and the outcome may not be as favorable as you’d like.  In this post, we’re going to break down the different types of OSHA violations you could receive and what each of them means.  Possible penalties will be posted as the current number followed by the new number in parentheses, which take effect August 1st.  Keep in mind that these penalties are for federal OSHA.  State run programs may be different.

De Minimus

A de minimus violation is a violation that comes without monetary penalty.  This may occur because OSHA recognizes that the violation, while non-compliant, poses no actual risk to the employee.  An example of this has been cited numerous times in this blog:  If somebody working on a roof – not performing roofing work, but something like HVAC installation – sets up a warning line 15’ from the edge of the roof, this is technically not compliant with OSHA regulations, however, OSHA recognizes that there is little to any risk to the employee.  Therefore, OSHA has noted that they would issue a de minimus violation for this.  For this type of violation, a citation is not issued.  Instead, it is discussed verbally between the compliance officer and the company in violation and a note is made in the inspection file.


(up to $7,000 per violation/up to $12,500 per violation)

This classification is reserved for violations that do not pose an immediate physical threat to your employees.  In other words, if you are in violation of a regulation such as being unable to provide proper recordkeeping documents or some instances of improper storage of materials, you could be issued an other-than-serious citation.  There is much flexibility with the dollar amount at which OSHA will set this fine.  Sometimes an other-than-serious will be accompanied by no penalty at all. 


($7,000/$12,500 per violation)

Serious violations are just like they sound.  With these types of violations there is significant chance of injury or death.  Serious violations can be assessed when companies should have known of a hazard but didn’t, or insufficiently protected their employees.  OSHA must assess $7000 per violation ($12,500 after August 1 of this year), but can adjust for a number of factors including company size.  A situation where an employee has been provided insufficient fall protection equipment could be cited as a Serious violation.


(up to $70,000 per violation/up to $125,000 per violation)

If Serious is serious, then Willful is extremely serious.  This classification is when somebody intentionally violates OSHA regulations or knowingly and willingly puts their employees in harm’s way.  In the event of a fatality, this becomes a criminal situation.  Perhaps a company has had people injured in scaffold collapses due to poor construction and continues to put their employees on that bad scaffolding.  This could earn them a Willful violation.  In a fatal situation, the fines come with a minimum of $250,000 for an individual and $500,000 for a corporation, as well as possible jail time of 6 months (double if it is a second conviction).



This is a violation of an OSHA regulation for which the company has already been issued a citation within the last three years (unless that citation is currently under appeal).  Understand that this does not have to be at the same location or even the same state, so it is in your best interest, as a company, to ensure you are communicating the results of an OSHA inspection and all lessons learned between all offices/projects within your company.

Failure to Abate

When OSHA issues you a citation, they give you a date by which you must abate it.  Failure to do so could result in a penalty of $7,000 for each day you fail to abate the violation.


Falsifying Records – OSHA can bring a criminal fine of $10,000, up to 6 months in jail, or both.
Violating Posting Requirements - $7,000
Assaulting a Compliance Officer (or otherwise Resisting, Opposing, Intimidating or Interfering with) – This is a criminal offense.  An offender could be fined up to $5,000 and face up to 3 years in prison.

As they say, “an ounce of prevention is worth a pound of cure.”  Do everything you can to keep your workers safe and stay compliant so that you will not need to know the difference between the various citations.  But, if you find yourself facing one (or many) don’t be afraid to reach out for help.  The citation/abatement problem can be a minefield for those unfamiliar with the process and a consultant can help you navigate it safely. 


HVAC Installer Dies After Fall Through Skylight

HVAC Installer Dies After Fall Through Skylight

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:

  1. 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. 

  2. “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.

  3. 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.

  4. 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.

Selecting Non-Penetrating Rooftop Anchors

Selecting Non-Penetrating Rooftop Anchors

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.

Common Hazards While Servicing Rooftop HVAC

Common Hazards While Servicing Rooftop HVAC

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?

Material Transfer

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.

Roof Damage

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.

Roof Distances By the Numbers

Is Your Safety Program Human-Proof?

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).

19 Inches

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.

4 Feet

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.

6 Feet

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. 

10 Feet

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.

15 Feet

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.

25 Feet

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.

50 Feet

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.

60 Feet

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.


OSHA and Illegal Immigrants

Is Your Safety Program Human-Proof?

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?  

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