OSHA’s Top 5 Fall Protection Violations – Part 2


Ranking number one on the list for six years in a row are violations related to the standard for fall protection. In our previous post we highlighted the 5th most cited fall protection section 1926.501(b)(4)(i): Holes and Skylights.

In this article, we take a look the 4th most cited section of the fall protection standard in fiscal year 2016:

1926.501(b)(11) “Steep roofs”

Each employee on a steep roof with unprotected sides and edges 6 feet or more above lower levels shall be protected from falling by guardrail systems with toe boards, safety net systems or personal fall arrest systems.

This section was cited 542 times in 2016, almost 3.5 times as much as number 5. Compared to 2015, when “Steep roofs” came in 4th as well, there are no significant changes in the number of citations: 523.

What does this section mean?

Putting this standard into practice, we need to explain how OSHA defines a steep roof. According to section 1926.500, a steep roof means a roof with a slope greater than 4 in 12 (vertical to horizontal). So, for example, when stretching 12 feet horizontally, the difference in height is greater than 4 feet. In practice, these are roof that have a slope of 18,6° or more.

Roofs that have a slope of 4 in 12 or less (≤ 18,5°) are referred to as low-sloped roofs.

The risks on steep roofs

Regarding the information provided above, the first assessment that has to be made is to determine if a roof is steep or not. The biggest danger is that the person assessing the slope of a roof trusts on visual evaluation only and possibly identifies the roof as a low-sloped roof instead of a steep roof, while the required safety measures between the two vary.

As can be seen in the image, a low-sloped roof is visually not that steep at all, which means a roof has to be labeled as steep fairly quickly. Especially in residential construction, where the most common roof pitches are 26,6° and higher, a large part of the roofs is steep and specific fall protection is required.

The fact that steep roofs might not SEEM steep and a worker feels comfortable walking and working on it, quickly result in (unknowingly) violating the 1926.501(b)(11) standard.

Eliminating the risk of falling off a steep roof

OSHA points out that when working on a steep roof, three fall protection measures can be taken in order to comply to the 1926.501(b)(11) standard:

Guardrail systems with toe board

Equipping a steep roof with a guardrail solution is mainly applied in industrial construction. Note that only guardrails with toe boards comply to the OSHA standard for steep roofs. This solution stops a potential fall off the roof and prevents tools, debris and other materials from falling down, protecting the ones working/walking below as well.

Although this solution provides a safe working environment on steep roofs, a potential objection can be that it harms the aesthetical value of the building in case of a permanent solution. Furthermore, residential construction and residential roofs often require different measures. Placing a guardrail system on a house isn’t the most preferable option in terms of costs and looks.

Guardrails can be placed temporarily as well, but installing and uninstalling this from time to time costs effort and is time consuming. This must be taken into account when looking for a solution.

Safety net system

This solution is mostly used on higher buildings and is pretty straightforward: a net (or ‘netting) is installed as close as practically possible to the working surface to prevent workers from falling down entirely. It can be installed permanently as well as temporarily.

These nets need to extend at least 8 feet from the structure and not more than 25 to 30 feet below the level where men are working. This means, workers can still fall a maximum of 25 to 30 feet which is never desirable! Besides that, the consequences for the aesthetical value of the structure are the downside of this solution.

Personal fall arrest system

The two measures mentioned above are generally solutions that affect a building’s aesthetical value and are applied to industrial construction. The third option that can be considered as a fall protection solution for work on a steep roof is a (permanent or temporarily) personal fall arrest system. In general, work on a residential building is most common as it comes to working on a steep roof.
Three possible solutions outlined in this article are a sling, a jamb anchor and a fixed anchor point. We will shortly discuss the solutions below. For more detailed information, read our blog about working on sloping roofs.

Using a sling

A sling is a strap, made from polyamide, that is tied to a strong living tree or the towing eye of a van for example, on the opposite side of the location where is being worked. Workers tie themselves to the rope to be able to access the roof safely.
This temporary solution is most common in residential work, because of its simplicity, cost effectiveness and the fact that it leaves no damage (except when an anchor needed to be drilled in the wall. In that case, the drilling holes remain).

Using a jamb anchor

A jamb anchor is a solution, designed to be mounted in a window or door frame. The anchor is in fact a tube with clamps on the side that clamp themselves between the frames of doors and windows. Because the tube is wider than the opening, the anchor is jammed and can be used as anchor point.
Workers connect a rope to the safety eye on the jamb anchor and connect themselves to the rope that runs over the roof to the other side of the building.

Using a fixed anchor point

If the situation doesn’t allow the use of the two solutions above in residential or industrial applications, fixed anchor points are an option.
In residential applications or other lower buildings with a steep roof, an anchor point is mounted on a wall or facade to be able to install a lifeline, run it over the roof and connect a worker to it. The anchor point can be removed after the work is done if desirable, only leaving the drilling hole.
In low-, mid- or high-rise construction where running lifelines over the roof is no option, permanent anchor points with lifelines can be considered (Horizontal Lifeline System), depending on the demands and design of the building. Workers can attach themselves to the lifelines or the anchor points using a lanyard and wearing a harness.

Situation specific solutions

Keep in mind that for every situation, a specific fall protection solution is best to use regarding the demands and design of the building. In order to determine which solution fits the needs, always consult a fall protection expert that can perform a risk inventory and evaluation (RI&I).

Top 5 section violations infographic

We have created an infographic based on the 5 most cited sections within the Fall Protection standard. In this infographic we have visualized the top 5 violations and provide solutions and advice on how to create safe working conditions in these situations and comply to the OSHA standards.

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