Falls from roofs, or other heights, are the number one cause of death for roofing installers.  In 2009, there were 283 falls on construction jobsites that led to serious injury or death. The reality is that falls can easily be avoided by utilizing the appropriate fall protection gear. The importance of utilizing fall protection is under renewed scrutiny by the U.S. Department of Labor’s Occupational Safety and Health Administration (OHSA) and the fines for non-compliance can be crippling to roofing contractors.

Residential construction employers need to comply with the agency’s new directive to provide residential construction workers with appropriate fall protection. OSHA has implemented a three month phase-in period for the directive, which began on June 16 and runs until September 15, 2011. During the phase-in period contractors who are compliant with the old directive (STD 03-00-001) will receive a hazard alert letter informing the employers of the fall protection methods available, but also reminding contractors that they need to have a site-specific fall protection plan in writing.  If the contractor complies with the old directive it is likely that OSHA will not issue fines or stop the contractor from working until the contractor complies with the fall protection directive.

However, if the roofing contractor is not complying with the old fall protection directive, OSHA may enforce the new directive, and issue fines against the contractor.  OSHA also has authority to require a jobsite to be shut down until the site comes into compliance with the OSHA regulations and/or directives.

The Citation Policy includes;

1. If an employer is engaged in residential construction, but does not provide guardrail systems, safety net systems, personal fall arrest systems, or other fall protection allowed under 1926.501(b), a citation for violating 1926.501(b)(13) should be issued unless the employer can demonstrate the infeasibility of these protective measures or the existence of a greater hazard.
2. Under STD 03-00-001, the employer was not required to have a fall protection plan that was written and site-specific. With the cancellation of STD 03-00-001, fall protection plans under 1926.502(k) must be written and site-specific.

Roofing contractors have argued that fall protection can get in the way of the work they perform because of the way it is tethered on the roof.  Fall protection manufacturers have tried to address this concern by creating feasible controls that can be put in place to protect the workers from fall hazards and not create tripping hazards for contractors that work on roofs. OSHA’s Residential Fall Protection page is a great resource for contractors and provides several documents that are easy to navigate and understand. One of these, Guidance Document on Fall Protection in Residential Construction is an excellent resource that provides examples of new protection gear and how they work.  It also provides photos, brief explanations, and is easy to follow. The Public Residential Fall Protection Presentation provides details on guardrail and safety net systems.

As a manufacturer of roofing materials, CertainTeed is committed to safety in the production and application of construction products.  We also feel that it is important  that you abide by OSHA directives in order to avoid placing your employees or workers in unsafe situations that could result in fines or a shutdown of a jobsite.  Creating safe practices in the workplace and on the jobsite protects the business and its employees.  Choose safety first.

Dennis Wilson is Manager, Product Stewardship for CertainTeed/Saint-Gobain.