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Fall Protection Standards

By Dominique Zellmer, Environmental Compliance Specialist, MMA

March 5, 2018

Danger Risk of Falling signProtect yourself: follow fall protection standards when working on a roof. A simple start is to identifying fall protection needs for a roof is to focus on high-frequency use areas like access points. Let’s say your roof is accessed by an external fixed ladder and has an HVAC unit that has quarterly maintenance requirements, an exhaust fan that gets a new belt once a year, and roof drains that are cleaned twice a year. Let’s break that down by each location and the frequency with which they are visited:

  • HVAC unit – four visits/year
  • Exhaust fan – one visit/year
  • Roof drain – two visits/year

Many people might say to protect the HVAC unit area first given the frequency of visits. However, it is important to remember that the hazard with the highest frequency is actually the ladder. At 14 visits per year, it would be considered having regular use. Additionally, no other unit brings your employee closer in proximity to danger than the ladder.

OSHA addresses this proximity to danger. According to the new fall protection standard for general industry, published in November 2016 and effective in Minnesota on September 19 2017:

1910.28(b)(3)(iv) – Each employee is protected from falling into a ladder way floor hole or ladder way platform hole by a guardrail system and toe boards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset must be used.

Ladder ways must be protected. If your roof is accessed via a roof hatch, OSHA states in 1910.28(b)(3)(v)(A) that “When the hole is not in use, the employer must ensure the cover is closed or a removable guardrail system is provided on the exposed sides.”

In reality, many people do not actually close the hatch. Most leave the hatch open, leaving an open hole on the roof. A railing and a gate surrounding the hatch help mitigate this risk without relying on the employee to manually open and close the roof hatch after every use, or inadvertently locking themselves out.

We encourage you to assess your rooftop access points for compliance. Additionally, conduct an assessment of all the fall protection needs in your facility. If you require additional assistance, please contact your MMA Environmental representative. An organized plan will pay for itself in no time.

This document is not intended to be taken as advice regarding any individual situation and should not be relied upon as such. Marsh & McLennan Agency LLC shall have no obligation to update this publication and shall have no liability to you or any other party arising out of this publication or any matter contained herein. Any statements concerning actuarial, tax, accounting or legal matters are based solely on our experience as consultants and are not to be relied upon as actuarial, accounting, tax or legal advice, for which you should consult your own professional advisors. Any modeling analytics or projections are subject to inherent uncertainty and the analysis could be materially affective if any underlying assumptions, conditions, information or factors are inaccurate or incomplete or should change.