While falls from flat and sloped roofs continue to rise across the country, roofing employers are faced with a mounting dilemma: How do I IMPLEMENT my fall protection program? How do I ENFORCE safe work practices among my employees? Whether or not your employees chose to follow your fall protection program or wear their personal fall arrest equipment, their health and safety is ultimately your sole responsibility. Perhaps the solution to both the implementation and enforcement problem is to involve your employees in their fall protection program and encourage them to participate in hazard control selection. Safety programmers all agree that unless workers are confident of the following three items, any program’s success will be unsubstantial and short-term:

• My employer’s first concern is my personal safety and health, not profit loss due to my accident or injury.

• My employer is making a “good faith effort” to reduce hazards in my workplace by engineering controls, safety training and personal protective equipment.

• By actually seeing the results of my safe work practices every day, I believe that “zero accidents” is an achievable goal.

Working in construction since 1966, I donned my first safety belt and lanyard as an apprentice carpenter walking scaffolding 38 feet high. I have seen the regulations, trade practices and equipment evolve over the last 35 years, but the relationship between a worker and his/her fall protection equipment has changed little. These days, I audit, train and consult with many residential, commercial and industrial contractors in the Northeast. From direct interviews with workers, I see their frustration with fall protection equipment and methods. In this column, I will identify some of the criteria that many construction workers have expressed to be important when evaluating their fall protection program and selecting their personal fall arrest system (PFAS) equipment.

Site Applicability

Most construction sites are usually too remote for the employer to visit on a regular basis or for prolonged periods. Employers rarely make their way up to those elevated areas where workers “hang out.” They will most often make ground inspections and receive tune-up reports from middle management. A job safety analysis (JSA) in the bid phases can not only protect an employee from a potentially unconsidered hazard, but also enable the employer to design his project around safety first. This can prevent lost time whenever the workers try to “invent” solutions on the job with whatever’s on hand at the time.

How do you assess your workers’ on-site fall protection requirements?

• Regular construction site visits

• Employee interviews or surveys

• Foreman’s job reports

• Occasionally working alongside crew members

Does your written fall protection program provide for:

• Annual review and input from workers?

• Categorizing different roof types?

• Competent Person hazard assessment criteria for environmental conditions?

• Ability of the CP to take prompt measures to correct identified fall hazards?

• Employee pre-exposure and refresher fall-protection training?

Task Feasibility

Many workers complain that the PFAS equipment they are given is either infeasible to use on a particular work site or when actually used, creates a condition that is more hazardous than originally assessed. Such conditions do not release the employer from developing a feasible protection system. It is often the duty of a few highly trained personnel to incorporate well-planned and often difficult site procedures in order to install PFAS components for the rest of the production crew to use at a later date. Many simple, low-cost solutions could be obtained if everyone involved attended and participated in pre-construction briefings and post-construction debriefings.

• Is your written fall protection program capable of adaptation to each and every roofing site where you may potentially place an employee?

• Do you perform regular JSAs and share the results with your workers?

• Do you conduct pre-construction briefing meetings to discuss CP designations, PFAS anchorage selection criteria, guardrails vs. PFAS evaluation methods, and “worst-case” rescue scenarios and drills?

• Do you conduct job debriefing meetings with your crew to determine how to improve rooftop safety, evaluate when a protective system puts roofers at risk, discuss improvements in the “first-man-up” procedures and perform PFAS equipment inspections?

Comfort

Without a doubt, discomfort is the foremost complaint by workers with any PFAS. Let’s face it. When it comes to spending eight hours in a full-body harness, no matter what you paid for it, if it is uncomfortable for any reason, they will either unfasten it to give them “breathing room” or else hang it on a nail in the back of the job trailer. The former is far more dangerous, as a worker without a harness is easier to spot than one with a loose leg or unfastened chest straps. The best means to enforce your fall protection program is to provide comfortable equipment that the workers can at least tolerate, if not enjoy, wearing.

• Have you designated a CP in writing to provide PFAS fit tests and training to your workers?

• Have you provided workers with a range of harness styles?

• Has your CP properly measured and fitted each worker for a full body harness and logged results on a regular basis?

• If you have female roofers, have they been offered a harness designed specifically for women?

• Does your PPE program include employee training in how to inspect and maintain their PFAS?

• Does each roofer have the capability to tag any component of the PFAS “Out of Service”?

Adaptability

If the fall protection budget is to be kept to a minimum, employers should be evaluating their PFAS for the ability to be used by more than just a few employees and at almost all of the potential elevated work sites. Even if a full-body harness and lanyard are inexpensive, they won’t necessarily save you a dime. If they cannot fit anywhere within a particular site’s fall protection SYSTEM, then there is no system.

There are horizontal and vertical lifelines (both tensioned and cantenary), cable and nylon retractable lifelines (now up to 200 feet), trailing ascent devices, single- and double-shock-absorbing lanyards, wire rope static lines and fastening devices, all of which may figure into a roofer’s fall protection system. There as many devices and pieces of equipment as there are protection problems and means to eliminate them. It’s the employer’s concern that any item purchased be adaptable to both his existing system components as well as his proposed ones.

Cost

It would be unrealistic to discuss the employer’s mandated duty to provide fall protection without discussing the cost factors involved. While most purchasers of PFAS equipment think the prices are unconscionable, most of it goes into overhead, not profit. The cost of developing new technologies and materials as well as the budget “pool” for potential litigation and settlements is astronomical for most manufacturers. While most of the PFAS products on the market today fall into the mid-price range, every manufacturer provides low-end items as well as high cost, custom products for specialty trades.

Depending on your requirements derived for a JSA, this is an area where you get exactly what you pay for and nothing more or less. Be accurate in assessing your needs in detail before investing in PFAS that may not protect adequately. The table (WHERE) lists just a few of the features and approximate cost ranges for typical extra-large full-body harnesses and shock-absorber lanyards. The actual manufacturers’ list pricing and offered styles and features may vary.

There is often much more to a PFAS than a simple harness and lanyard. There may be man-rated items such as beam clamps and trollies, nylon or cable retractable lifelines, mono and multi-point anchorage devices, carbiners, ascenders and descenders, vertical 5/8-inch lifelines and rope grabs, horizontal static lines, fasteners and bypass standards. As a result, the preplanning involved in a fall-protection system designed by the competent person can be quite extensive. The training and equipment for the “first man up” who installs the PFAS can also be intensive. Preparing for the budgetary loads ahead of time will not only make your elevated job site safer, but up and working sooner.

Summary

According to 29 CFR Part 1926.501(a), the primary duty to determine the level of fall protection and the scope of a fall protection program rests solely with the employer. The obligations of the roofing employer are further specified by the threshold criteria listed in 1926.501(b)(10) and (11) as well as Appendix A to Subpart M. The OSHA regulations portray a wide variety of fall prevention measures as well as fall arrest devices and systems should a fall occur. Thoroughly training your roofers in Subpart M: Fall Protection and encouraging them to become involved in designing site-specific fall protection solutions will protect them and you from the high cost of a fall accident.

Just recently, my friend David fell 25 feet off an 8:12 metal roof, through an unplanked frame scaffold tower into the frozen excavation below. At the time, he was using the hex heads of the deck screws to grip his boot treads. Miraculously, he only suffered bruised ribs, sprains, contusions, pinched nerves and extensive lacerations from attempting to grab the leading metal edge to stop his slide. I called him at home while he was recovering, and he was in the midst of trying to pick up a video off the floor with a yardstick and duct tape.

I mentioned that I was writing a fall-protection article for roofers and asked if he had anything he would like to contribute. This is what David had to say: “Everyone I know occasionally buys a lottery ticket. Every last one of them believes that there is at least some chance that they could win. But if they’re ever on a roof, they should seriously consider that they are much more likely to fall off a roof than win with that lottery ticket. I was only up on the roof for 10 minutes to screw the last ridge cap in place. If I didn’t fall, I would have finished in five minutes. Later, it took another roofer an hour to prepare the roof with PFAS and finish the ridge cap safely. That extra hour could have saved me weeks of rehabilitation, lost income and possibly my life. We all know that 99 percent of the time, accidents don’t happen. What we forget is that 1 percent of the time, they do. I’m going to take all the time we need to prepare for that 1 percent.”

Before David hung up, he thought of one more thing he wanted to add: “This is really important. Tell them that if they ever fall off a roof, not to expect any sympathy from anyone. It’s just not going to happen.”