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2022 OSHA Inspection Prep Part One: Rooftop Fall Protection

• Jun 12, 2022

If you’ve ever experienced an unexpected visit from an OSHA inspector, you know how important it is to be prepared. If you haven’t, consider this: OSHA has jurisdiction over 7 million worksites and, even in the midst of the COVID-19 pandemic in 2020, they still conducted over 21,000 inspections. These inspections are often unannounced, and since OSHA cites falling from heights as one of the most common causes of workplace injury, it pays to ensure that your rooftop fall protection is in full compliance ahead of time. 

When it comes to preparing your rooftop for inspection, there are five main areas of concern: access, edges, equipment, openings, and navigation.
 
Let’s closer look at the five areas of concern:

1). Access 
While it’s logical to assume that most falls occur once people are on top of the roof, accessing the roof itself presents serious risk if the right roof fall protection systems aren’t in place. Your access point checklist should include:

• Access Control. Ladders, stairs, and hatches should both restrict unauthorized access as well as meter traffic flow. Ladder guards will prevent access from the bottom, while a combination of safety railings and a self-closing gate on the rooftop slows traffic and provides a safe barrier.
• Fall Protection. According to OSHA, for fixed ladders that extend more than 24 feet (7.3 m) above a lower level, the employer must ensure that each fixed ladder installed before November 19, 2018 is equipped with a personal fall arrest system, ladder safety system, cage, or well and that each fixed ladder installed on and after November 19, 2018, is equipped with a personal fall arrest system or a ladder safety system.
• Visibility & Obstruction: Ensure your access points are well-lit and free from obstruction.  

2. Edges
Once you’ve accessed the roof, it’s time to assess the edges and open sides. Keep in mind that even roofs with parapet walls may need a metal guardrail to supplement fall protection—not all parapets meet OSHA standards. Regulations state that parapets and safety railings have to be 42 inches tall, plus or minus 3 inches, to provide adequate fall protection. When it comes to auditing your edges, check off the following:

• Eliminate Trip Hazards. The roof top should be free from obstructions and trip hazards like ropes, power cords, tools, and other building materials. 
• Install Safety Railings. Passive roof fall protection systems like guardrails and safety railings, add a layer of protection that requires no active participation from rooftop workers. 
• Provide Personal Fall Arrest Systems. Some rooftop work may fall outside of the protection of a guardrail. For this type of work, provide personal fall arrest systems and the necessary training required to use them. 

3. Equipment
Many industrial rooftops are home to large scale equipment like HVAC systems and, on older buildings, water towers. Both workers and vital equipment need to be protected. Here’s what to do:

• Evaluate Potential Risk Areas. Check to see how close to any open sides or edges any rooftop HAVC units or similar equipment are.
• Provide Fall Protection. If equipment is too close to the edge, a guardrail system can be an ideal solution to protect employees and any outside service workers. 

4. Openings 
Be sure not to overlook rooftop openings like hatches and skylights; these potential fall hazards require protective equipment to keep rooftop workers safe. Make sure that you:

• Surround Hatches. Hatches should not be left without barriers around them. Select safety railing systems and gates specifically designed for protecting rooftop hatches.
• Cover Skylights. Skylights present a fall risk— make sure you cover them with a skylight protection system or barricade them with guardrails. 

5. Navigation
Once someone has accessed the roof, they need to be able to easily navigate their way around—day or night. 

• Lighting. Rooftops should be well-lit. In addition, railing systems should have warning lights to ensure safety for nighttime work. 
• Topography. If your roof has multiple levels, make sure terrain is well-marked with yellow warning strips. Likewise, ensure any equipment is also marked and, if necessary, guarded by safety rails, so workers can safely navigate their way around. 

Above and Beyond Rooftop Fall Protection
In addition to providing the right roof fall protection systems, OSHA also requires companies to have rescue and emergency plans in place, as well as keep detailed records of safety training and previous incidents:

• Rescue Plan for Workers. Your company must have a rescue plan in place in the event of an emergency—like assisting someone suspended in a harness. This means having rescue personnel, ladders, and other equipment on hand. (See OSHA 1910.140(c)(21)).
• Emergency Action Plan. OSHA requires companies to keep an emergency action plan (1910.38), which should include means of reporting emergencies and how to evacuate the area (1910.38(c)). First-aid materials must be accessible (1910.151). All workers should know the street address of their employer and worksite in case of an emergency, and at least one on-site employee should have first aid training. 1910.151. 
• Detailed Safety Records. OSHA requires employers to record any professional training their workers receive to achieve and verify compliance. Likewise, you’ll need to provide any worker compensation records, insurance claims, and any independent audits. 

The Rising Cost of Non-Compliance
Of course, no business wants to put their employees in harm’s way. But on top of the risk of injury, non-compliance can result in costly penalties. The fines for penalties have risen several times over the past few years, and for worksites assessed after January 15, 2022, maximum penalties are as follows:

• Serious / Other-Than-Serious / Posting Requirements: $14,502 per violation
• Failure to Abate: $14,502 per day beyond abatement date
• Willful or Repeated: $145,027 per violation

Keep in mind, these penalties apply to all federal OSHA states. State-level local occupational safety and health programs often align their penalties with these standards as well.

Keep Your Company and Employees Protected
No one looks forward to an OSHA inspection—they can slow down projects and workflow, cause stress, and often result in costly fines. With the proper prep and the right rooftop fall protection in place, you’ll be ready when the inspector comes knocking. If you aren’t sure where to start when it comes to rooftop safety, contact an experienced fall protection solutions provider that can help you complete a full assessment of your rooftop. This will provide you with a proper starting point for ensuring your facility is compliant with all current OSHA regulations.