The OSHA fall protection standards have elements that touch all industries and complying with them can be challenging. The General Industry standard addresses fall hazards under Walking-Working Surfaces in 1910.28 while the applicable Construction Industry standard is Subpart M 1926.500-503. Let’s take a closer look at one of the most commonly asked questions regarding fall protection. What are the requirements for workers conducting maintenance on a flat roof?

We asked this question of David Kozlowski, the president and owner of Safe Approach in Poland, Maine. His firm designs and builds fall protection equipment and implements fall prevention solutions for all industries. David was our guest on a recent episode of the MEMIC Safety Experts Podcast- the entire podcast can be heard here. For David, the first step is to get past the uncertainty of most business owners. “If you've never fallen off a roof or had an injury like that,” he said, “it can be difficult to understand why you need it.” Once the initial resistance is overcome then creative solutions can be implemented. This can still present a big challenge as Kozlowski acknowledges, “We haven't invented the perfect integrated and seamless system yet.” While it is true that comprehensive systems can still be costly, that isn’t a consideration by OSHA, and we all know the cost of any fall protection system is far less than the cost of a serious fall injury.

So how do we protect the maintenance worker who is on a flat roof occasionally to change HVAC filters? The applicable standards are 1910.28(b)(13) Work on low-slope roofs and 1910.29(d) Designated areas.

Let’s breakdown these standards so a clear picture emerges. 

• First, determine if the roof is a “low-slope roof,” defined as a slope of 4:12 or less.
• Next, determine if these standards are the proper standards to follow. The deciding factor is the type of work the employee is performing. According to OSHA in a 1999 letter of interpretation, "Maintenance" means keeping equipment or a structure in proper condition through routine, scheduled or anticipated measures without having to significantly alter the structure or equipment in the process. For equipment, this generally means keeping the equipment working properly by taking steps to prevent its failure or degradation. Thus, changing an HVAC filter, replacing other parts on a scheduled basis, or cleaning a unit is not defined as “construction” so this situation falls under this 1910 standard.
• If workers are within 6’ of the roof edge they must be protected using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. No other options are provided by OSHA. For the purposes of this post, we are not considering the construction industry safety monitor system.
• When workers are between 6’ and 15’ from the edge the same fall protection is required unless the work is “infrequent and temporary.” In this case a designated area can be used.
  • Infrequent is defined as once a month or less, while temporary is less than two hours in duration (defined in the standard preamble).
  • The method to delineate designated areas are contained in 1910.29(d). There must be a warning line, rope, chain, or tape that has a minimum breaking strength of 200 pounds installed 34-39 inches above the surface, be clearly visible from 25 feet away, and erected as close to the work area as the task permits (not less than 6’ from the roof edge for temporary and infrequent work).
• When workers are more than 15’ from the roof edge engaged in work that is temporary and infrequent, no fall protection is required. If the work is not temporary and infrequent, a designated area must be delineated with the warning line system placed at 15’ from the roof edge (or further from the edge if closer to the work being performed) to delineate a designated area.

Kozlowski’s best advice is to start thinking about the roof “as simply another floor of the building.” The roof is a floor that has open edges and potentially many unprotected openings or holes. These standards allow some flexibility for employers such as permitting work within designated areas that warn workers of nearby fall hazards, yet free them from personal fall arrest systems and decrease the need for extensive guardrail systems. At times a “hybrid” system might be necessary such as combining designated areas with railing systems. This is especially helpful when providing a safe method of reaching work areas and/or accessing a roof from a ladder.

OSHA provides many resources on this topic including fall prevention for construction workers, GI Walking-Working Surfaces OSHA Fact Sheet, and the OSHA Publications devoted to all aspects of fall prevention. Ensure your employees are as safe as possible while working on low-slope roofs. Remember, with an acceleration rate of 32’/sec² gravity will always win.   

Posted ByRandy Klatt, (Retired May 2022)