Know the Standards to Avoid Rooftop Falls


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The career path taken by HVAC technicians is one that is full of a variety of obstacles that require focus, dedication, and a solid knowledge of safety rules and regulations.

A technician can often be required to slide into a crawl space, manipulate their way under a building, or into an attic. All of these tasks are dangerous but one task required of HVAC technicians, working on rooftops, is especially precarious and requires employers to provide specific fall protection and abide by certain standards.

From OSHA Safety and Health Regulations for Construction (Standard 1926.01)

General Industry – Fall Protection

When performing HVAC maintenance on roofs,1 OSHA’s general industry standard §1910.132(a) would apply. On commercial roofs, HVAC units typically are located near the center of the roof, which may significantly reduce the fall hazard exposures. However, where the potential for falls exists, protection must be provided.

Note for HVAC technicians in regard to different regulations for construction workers:

OSHA’s fall protection standard for construction, 29 CFR Part 1926 Subpart M (beginning at §1926.500), generally requires fall protection when there is a fall distance of 6 feet or more. In a few, very specific situations (low-slope roof work, some leading-edge work, precast concrete erection and residential construction; see §1926.501(b)(2), (12), and (13)), because of feasibility limitations, the standard permits the use of a warning line, in combination with other measures, instead of conventional fall protection (guardrail systems, personal fall arrest systems or safety net systems) to keep employees away from an edge.

Installation of HVAC equipment does not fall within the categories: leading-edge work, precast concrete erection or residential construction. Therefore, the warning line at the 6-foot option does not apply.

As explained in the August 1, 2000, Troxell letter, where certain conditions are met, the use of a warning line 15 feet back from the edge will be considered a de minimis violation of the guardrail criteria in §1926.502(b). The conditions that must be met for the application of this policy are as follows:

  1. A warning line is used 15 feet or more from the edge;
  2. The warning line meets or exceeds the requirements in §1926.502(f)(2);
  3. No work or work-related activity is to take place in the area between the warning line and the edge; and
  4. The employer effectively implements a work rule prohibiting the employees from going past the warning line.

Therefore, where these conditions are met, you may use a warning line 15 feet back from the edge to protect the HVAC workers.

The following sections apply to HVAC technicians working on rooftops:

  • 501(a)(2)

The employer shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely. Employees shall be allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity.

  • 501(b)(1)

“Unprotected sides and edges.” Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.

  • 501(b)(4)(i)

Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.

  • 501(b)(4)(ii)

Each employee on a walking/working surface shall be protected from tripping in or stepping into or through holes (including skylights) by covers.

  • 501(b)(8)(ii)

Each employee 6 feet (1.8 m) or more above dangerous equipment shall be protected from fall hazards by guardrail systems, personal fall arrest systems, or safety net systems.

  • 501(b)(11)

“Steep roofs.” Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems.

  • 501(b)(15)

“Walking/working surfaces not otherwise addressed.” Except as provided in 1926.500(a)(2) or in 1926.501 (b)(1) through (b)(14), each employee on a walking/working surface 6 feet (1.8 m) or more above lower levels shall be protected from falling by a guardrail system, safety net system, or personal fall arrest system.

Ruben Porras

Posted In: Commercial Buildings, Safety

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