FACILITY FALL PROTECTION: ROOF & FAÇADE MAINTENANCE

LJB WEBINAR – NOVEMBER 2012

MEG PHILLIPS, P.E., C.S.P.

MPHILLIPS@LJBINC.COM; 513-582-4782

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ROOF FALL HAZARDS

0

20

40

60

80

100

120

140

160

180

200

2002 2004 2006 2008 2010

Roofs

Ladders

Scaffolds

Non-movingvehiclesStrucSteel

Source: BLS Census of Fatal Occupational Injuries

3

BOTTOM LINE UPFRONT

Roof fall protection is challenging

＞ Various regulations

＞ Abatement strategies

You need a plan for:

＞ Access and safe distance policies

＞ Hazard identification

＞ Hazard abatement

4

AGENDA

Safe distance

Work classification

Common hazards

Abatement strategies

＞ Roof

＞ Facade

Closing

5

SAFE DISTANCE?

OSHA 1910 OSHA 1926 OSHA 1926 roofing non-roofing

6

SAFE DISTANCE?

Proposed 1910

OSHA 1910 OSHA 1926 OSHA 1926

roofing non-roofing

7

SAFE DISTANCE?

Proposed 1910

OSHA 1910 OSHA 1926 OSHA 1926

roofing non-roofing

8

SAFE DISTANCE?

Proposed 1910

Mech. Equip. Exception

OSHA 1910 OSHA 1926 OSHA 1926

roofing non-roofing

9

SAFE DISTANCE?

Proposed 1910

Mech. Equip. Exception

OSHA 1910 OSHA 1926 OSHA 1926

roofing non-roofing

10

SAFE DISTANCE?

Proposed 1910

Mech. Equip. Exception

15 feet de minimis

OSHA 1910 OSHA 1926 OSHA 1926

roofing non-roofing

11

OSHA 1910

OSHA 1910 does not provide a safe distance from the edge

Proposed OSHA 1910 - Designated area＞ Perimeter shall be erected no less than 10 feet from the unprotected

side or edge

12

OSHA 1926: ROOFING

OSHA (sec 1926.502(f)(1)ii) - “the warning line shall be erected not less than 6 feet from the roof edge which is parallel… not less than 10 feet…perpendicular to the direction of mechanical equipment operation.” Other exceptions: OSHA (sec 1926.500(a)(2) & 1926.501(b)(1-14)) ＞ Some leading edge work ＞ Precast concrete erection＞ Residential construction

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OSHA 1926: NON-ROOFING

No safe distanceOSHA letter of interpretation＞ For trades other than roofing, warning lines at 15 feet will be a de

minimis violation• Roofing Work and Other Trades on Low-Slope Roof (August 1,

2000)

• Warning line at 6 feet for HVAC construction workers (November 15, 2002)

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OSHA 1926: NON-ROOFING

Warning lines must meet 4 criteria＞ 15 feet or more from roof edge＞ Meet or exceed OSHA 1926.502(f)(2)＞ No work activity within 15 feet of roof edge＞ Work rules prohibit workers from going outside warning line

15

INTERNATIONAL BUILDING CODE

IBC (sec 1012.5) - “Guards shall be provided where appliances,

equipment, fans or other components that require service are

located within 10 feet of a roof edge.”

16

AGENDA

Safe distance

Work classification

Common hazards

Abatement strategies

＞ Roof

＞ Facade

Closing

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OSHA WORK CLASSIFICATION

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WHICH CLASSIFICATION?

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WHICH CLASSIFICATION?

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AGENDA

Safe distance

Work classification

Common hazards

Abatement strategies

＞ Roof

＞ Facade

Closing

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COMMON HAZARDS - ROOFS

Means of access

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COMMON HAZARDS - ROOFS

Openings

23

COMMON HAZARDS - ROOFS

Working near edge

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COMMON HAZARDS - ROOFS

Hoist areas

25

COMMON HAZARDS – FAÇADE

Window cleaning and maintenance

Architectural treatments

Flags/banners

26

AGENDA

Common hazards

Safety requirements

Abatement strategies

＞ Roofs

＞ Façades

Closing

27

HIERARCHY OF CONTROL

Defeatability

Effe

ctive

ness

Elimination

Substitution

Engineering controls

Administrative controls

Personal protective equipment (PPE)

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LETTERS OF INTERPRETATION - OSHA

Roof access openings require protection (July 12, 2000)

＞Guardrail for roof hatch openings

Fall protection requirements for roof construction (Dec. 15, 2003)

＞Use of warning lines for low slope roof work vs. other trades

29

ABATEMENT OPTIONS - OSHA

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OSHA STD 1-1.13 – DEFINITION

Any surface designed or used as a walking / working surface

＞For tasks performed on a predictable / regular basis

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OSHA STD 1-1.13 – REQUIREMENTS

FREQUENT TASKS:

＞ More than 1x every 2 weeks

＞ More than 4 hours over 4 week period

＞ Required to use engineering controls (guardrail)

LESS FREQUENT TASKS:

＞ Permitted to use alternative fall protection such as a personal fall arrest systems (PFAS)

32

AGENDA

Safe distance

Work classification

Common hazards

Abatement strategies

＞ Roof

＞ Facade

Closing

33

ELIMINATION/SUBSTITUTION

Place HVAC units on the ground

Design considerations for roof access via aerial lift

34

ENGINEERING CONTROLS

Guardrail

＞ Fixed

＞ Portable

Lifts

Fixed scaffold

35

ROOF PLAN

36

ROOF HATCH

37

ROOF FANS & SMOKE VENTS

38

SKYLIGHTS

39

ADMINISTRATIVE CONTROLS

Roof permit system

＞ Primary vs. secondary control

＞ Implementation

＞ Training

＞ Monitoring

40

ROOF PLAN

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THIS ISN’T WARNING LINE

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DESIGNATED AREAS

Proposed OSHA 1910 - Designated area＞Work of temporary nature such as maintenance on HVAC

＞Use warning line as alternative to installing guardrails

＞Surface slope must be 10 degrees or less

＞Perimeter shall be erected no less than 10 feet from the unprotected

side or edge

＞Access to designated area must be clear path with warning lines

43

PPE

Roof edge

＞ Fall restraint or arrest

• Rail

• HLL

• Anchor points with lifeline

44

PPE: ANCHORAGE POINTS

Fixed anchorage

＞ Structural steel?

＞ HVAC unit?

＞ HVAC curb?

Temporary anchorage

＞ Ballasted anchor?

45

PPE SOLUTIONS

Did you consider?

＞ Anchorage strength

＞ Fall clearance

＞ Swing fall

＞ Proper application

＞ Procedures and training

＞ Rescue

46

REVIEW

What classification, safe distance and solution would you apply here?

47

FINAL ABATEMENT

48

AGENDA

Safe distance

Work classification

Common hazards

Abatement strategies

＞ Roof

＞ Facade

Closing

49

FAÇADE MAINTENANCE

Aerial work platforms

Supported scaffold

Suspended systems

50

AERIAL WORK PLATFORMS

51

SUPPORTED SCAFFOLD

52

SUSPENDED SYSTEMS

53

INDEPENDENT ANCHORAGES

Capable of supporting 5,000 pounds

Located directly over the point of suspension

54

SUSPENDED SCAFFOLD ANCHORAGES

SAFE POINTSStructural members determined by qualified person

UNSAFE POINTSStandpipesVentsOther piping systemsElectrical conduitOutrigger beamsCounterweights

55

SUSPENDED SCAFFOLD OPTIONS

56

SUSPENDED SCAFFOLD OPTIONS

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ANSI I-14.1 WINDOW CLEANING STANDARD

Withdrawn by ANSI ＞ Revised standard being prepared by IWCA committee.

Independent anchorage for suspension lines and lifelines

Roof anchorage must be designed for the greater of 5,000 pounds or 4x the maximum applied load

15º rigging angle from point of suspension

Annual anchorage inspection

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AGENDA

Safe distance

Work classification

Common hazards

Abatement strategies

＞ Roof

＞ Facade

Closing

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ACTION ITEMS

Evaluate your program’s safe distance policies

Educate others about safe distances and work

classifications

Evaluate or develop a roof permit system

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TO LEARN MORE

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