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What Does OSHA Consider to be a Hole in the Roof?

Sometimes, when questions seem like they should have obvious answers, we need to dig a little deeper to make sure we’re not making assumptions. When it comes to what OSHA considers a hole in the roof, it would be easy to say, “A hole is a hole.” I mean, we all know what holes look like, right?

The trick to questions like this is figuring out what less obvious things might fall into this category. Or, what could be even more challenging, what does OSHA not consider a hole?

Let’s start with OSHA’s definition of a hole. In the construction fall protection standard, as well as in the general industry walking/working surface standard, it states:

“A gap or void, 2 or more inches in its least dimension in a floor, roof, or other walking/working surface.”

So, any opening in the roof in which the smaller side is greater than 2" we have a hole. This is important because many people assume a hole is something you at least have to be able to fit a foot into. But, if that were the case, why would OSHA make the requirement for the least dimension so small?

OSHA isn’t just concerned with somebody falling through a hole, they are also concerned with somebody tripping because of a small hole, or kicking/dropping something through a hole that could potentially injure somebody below. Small holes could also pose problems for ladder stability, forklifts, man lifts, scaffolds, and a wide array of other equipment used on a job site by making them even slightly unstable. So, many larger, more obvious holes get protected in the work area, but many of these smaller holes get overlooked or intentionally ignored because people feel that they don’t pose a real hazard or because it would be too time-consuming to bother covering them all.

As a reminder, all holes need to be covered, if not with a permanent cover, with something that would support at least 2x the maximum intended load, is prevented from movement, and is marked with the word “HOLE” or “COVER”.

Skylights are “holes” in Your Roof

Still, even knowing that smaller holes are included in the mix, this doesn’t seem like a very complicated answer. So, what about holes that aren’t actually holes? The key to this one is realizing that hole covers, regardless of type, don’t always meet the necessary requirements for protecting human life. The biggest culprit in this category would be skylights – and I don’t just mean skylights that are left open during construction. Finished, covered skylights can very well be considered holes.

Most skylight domes are not strong enough to keep a person from falling through. In fact, many of the cages you see covering domed skylights are also not capable of supporting the force of a falling person. These cages, as well as the domes, are usually designed for preventing water, small animals, and debris from entering the building. Yet, many people assume they are protected while working around them. Rooftop work is often performed without the slightest consideration for fall protection around these skylights, despite there being countless stories of workers falling through to their deaths, or at the very least, debilitating injuries.

Skylights come in other forms as well, such as fiberglass panels. These panels are weaker and more translucent than other panels on the roof in order to allow light into the building. Most will not hold a person’s weight and are difficult to differentiate from the regular panels when looking down into a dark building. They have become a concern for firefighters for this very reason.

Protecting Your Workers from Falling Through a Skylight

While personal fall arrest systems can be used to protect your workers, there are also products on the market specifically designed for skylight protection. Skylight screens and skylight guardrail systems are a compliant and cost effective way to protect your workers.

These products are a form of passive fall protection, meaning they don’t require special training or for a worker to do anything in order to be protected. When possible, passive fall protection should be preferred over active fall protection.

Recognizing Weak Spots

One other problem that is fairly unique to roofs, is the fact that the surface on which you are working is almost always covered by a membrane which prevents you from seeing the condition of the roof itself. Holes can exist that you simply cannot see. It is important to do a walkthrough of a roof before beginning work to see if you find any weak spots. Inspections from underneath, if possible, are a good practice as well. Knowing what a hole is, technically, will not help you if you don’t even know the hole is there.

Holes are not difficult to wrap your mind around but are probably also nowhere near as simple as you may have thought. Next opportunity you have, inspect your work area to see if you may have missed things that meet the definition of a hole, now that you know exactly what OSHA is looking at. And, as they say, “Knowing is half the battle.”

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This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

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John Braun has been in the EHS field for more than 16 years. He achieved his CHST in 2005 and his CSP in 2010. Though he focuses on construction, his background includes manufacturing, recycling, and warehousing facilities as well. John holds a Bachelor's degree in English from The College of NJ.

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