Author: Richard DiNitto
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Working on a roof can be a dangerous activity and is often considered part of an overall Fall Protection Program.  Fall protection is one of the most commonly cited violations by the Occupational Health and Safety Administration (OSHA). Nearly 900 people die annually in the US from falls from a roof. 

​Care in how you perform roof work is critical to your overall safety programs. Within the US, OSHA establishes requirements for roof work under Rule 1910.28 Duty to have fall protection and falling object protection.
 
Rule 1910.28 establishes that an employer must ensure that each employee on a walking-working surface (such as a roof in this case) with an unprotected side or edge that is 4 feet (1.2 m) or more (for general industry or 6 feet or more for construction work) above a lower level is protected from falling by one or more of several specified control measures:

• Guardrail systems;
• Safety net systems; or
• Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems.

 
Under the Rule, the distance from the edges of the roof dictates which systems must be in place and what allowances may be acceptable:

• < 6 feet (1.6 m) from the edge - When work is performed less than 6 feet (1.6 m) from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system.

 

• 6 to < 15 feet (4.6 m) - When work is performed at least 6 feet (1.6 m) but less than 15 feet (4.6 m) from the roof edge, the employer must ensure each employee is protected from falling by the same systems as above.  The one exception is that if the roof work is both infrequent and temporary, the employer may use a designated area when performing this work.

 
A Designated Area is defined by OSHA as "A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection."

• Beyond 15 feet (4.6 m) from the edge:
  • Frequent and not temporary work -  the employer must protect each employee from falling by a guardrail system, safety net system, travel restraint system, personal fall arrest system, or a designated area.
  • Infrequent “and” temporary - the employer is not obligated to provide fall protection, provided that:
    • The work is both infrequent and temporary;
    • The employee is working strictly beyond 15 feet (4.6 m) of the roof’s edges; and
    • The employer implements and enforces a work rule, prohibiting employees from going within 15 feet (4.6 m) of the roof edge.

 
These exceptions for using a designated area or not having to enforce a fall protection plan requires that the work is both temporary and infrequent.  These terms are defined as:

• Infrequent - Infrequent work means an activity is performed only occasionally, such as once a year, once a month or when needed but not a routine or regular task that might be on a daily or weekly basis.
• Temporary - temporary refers to tasks that usually takes less than 1-2 hours to complete.

 
As with any work activity that has inherit risks and safety concerns, a proper hazard evaluation or risk assessment to determine the best and safest approach is warranted.  While the information provided above is a good overview and guidance for safe work on a roof, the regulatory rules cover additional parameters and issues that you need to consider in your roof work evaluations and program.  Consultation with roof safety experts is strongly recommended. 

​The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities. 
 
If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at [email protected] or (617) 330-2800.

Saudi Arabia issued an amendment to its Work System Law in late July of 2019. Changes include the following:

• Redefining the definition of “agent”;
• Amending article 3 to state that citizens are entitled to work without discrimination on the basis of sex, disability, and age, among others; and
• Prohibiting the dismissal of pregnant employees and those on maternity leave.

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Additional Information:
https://sd.mlsd.gov.sa/ar/policies/%D9%86%D8%B8%D8%A7%D9%85-%D8%A7%D9%84%D8%B9%D9%85%D9%84-0. 

If you are interested in EHS regulatory products for Saudi Arabia, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or [email protected] for a customized quote.

​Russia issued Order No. 512H on Approval of the List of Productions, Works and Positions with Harmful and (or) Dangerous Working Conditions, on which the Use of Labor of Women is Limited. The Order determined in which industry jobs and positions with harmful and dangerous working conditions the use of women’s labor is limited. They include certain types of chemical production, underground and mining, metalworking, drilling, oil and gas production, ferrous and non-ferrous metallurgy, and shipbuilding. The order takes effect on January 1, 2021.
 
Additional Information: http://www.garant.ru/hotlaw/federal/1288007/. 

If you are interested in EHS regulatory products for Russia, the Isosceles Group provides a number of tools covering this jurisdiction including: EHS Legal Registers, EHS Audit Checklists, EHS Audit Checklist Supplements, EHS Quarterly Regulatory Updates, and more. Please contact Brittany Palmer at 617.330.2800 or [email protected] for a customized quote.

Author: Ellen Pinkos Cobb

​For the first time, violence and harassment in the world of work are covered in new international labour standards, adopted at the Centenary International Labour Conference and now open for ratification by ILO Member States. Before adoption of the Convention, there had been no international legal standard that addressed violence and harassment in the workplace or provided a definition and scope for it.
 
On June 21, 2019, at the International Labour Conference's annual meeting, the ILO adopted the new Convention and Recommendation to Combat Violence and Harassment in the Workplace. Conventions are legally binding international treaties that may be ratified by Member States, while Recommendations provide advice and guidance.

The Convention defines violence and harassment as "a range of unacceptable behaviours and practices" that "aim at, result in, or are likely to result in physical, psychological, sexual or economic harm". This potentially covers physical abuse, verbal abuse, bullying and mobbing, sexual harassment, threats, and stalking, among other things. The Convention also takes account of the fact that nowadays, work does not always take place at a physical workplace; so, for example, it covers work-related communications, including those enabled by information and communication technology.

Convention No. 190 will enter into force 12 months after two Member States have ratified it.

Source: 
Convention 190, Convention Concerning The Elimination Of Violence And Harassment In The World Of Work at https://www.ilo.org/wcmsp5/groups/public/---ed_norm/---relconf/documents/meetingdocument/wcms_711570.pdf.

​The Isosceles Group offers Workplace Wellness Assessments and Workplace Bullying Assessments and Checklists. If you would like Isosceles to develop an assessment for a particular jurisdiction, please contact Brittany Palmer for a quote at [email protected] or (617) 330-2800.