Working on a Roof
Author: Richard DiNitto
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:
Under the Rule, the distance from the edges of the roof dictates which systems must be in place and what allowances may be acceptable:
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."
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:
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 firstname.lastname@example.org or (617) 330-2800.
Saudi Arabia Amends Work System Law
Saudi Arabia issued an amendment to its Work System Law in late July of 2019. Changes include the following:
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@example.com 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 firstname.lastname@example.org 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.
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@example.com or (617) 330-2800.
Recently, a client asked us if fall protection railings are required on a loading dock that is more than four feet high. Our answer may surprise you.
After a comprehensive review of several documents, including proposed OSHA rules and publications, we advised our client to install railings on loading docks that are six feet (1.8 meters) or higher. While we still recommend railings on loading docks that are shorter than six feet, the railing must be installed in such a way as not to impede workflow. Finally, personnel working on a loading dock must have adequate fall prevention training—and no one should be on the loading dock unless absolutely necessary. In other words, the loading dock is not an appropriate place to take a cigarette or coffee break.
Relevant OSHA Regulations
The OSHA General Duty Clause. Employers will furnish “a place of employment … free from recognized hazards that are causing or are likely to cause death or serious physical harm.” This is the duty of care required of all employers and is relied upon when an OSHA regulation lacks clarity or detail. It is also the reason we recommend that our clients consider installing chains or railings on any active loading dock.
OSHA 1910.178(m)(6) Powered Industrial Trucks. This regulation requires that “a safe distance shall be maintained from the edge of ramps or platforms while on any elevated dock.” However, it does not define that safe distance.
OSHA 1917.112 (b)(1), Marine Terminals, Guarding of Edges. “Guardrails shall be provided at locations ... which present a hazard of falling more than 4 feet or into the water.” However, it goes on to say, “Guardrails are not required at loading platforms and docks.”
Other Relevant Guidelines
OSHA Publication 3220-10N, 2004 Pocket Guide Worker Safety Series Warehousing. This publication comes closest to addressing the question directly: “areas that employees could fall 4 feet or more or walk off should be chained off, roped off or otherwise blocked.” However, the use of the term “should” indicates that this is a guideline, not a requirement.
OSHA Proposed Rulemaking on Walking and Working Surfaces: April 1990. Published but never fully adopted, this proposal was referenced in a December 1997 Standards Interpretation letter and states: “employers would not be required to install guardrail systems on the working side of platforms, such as loading docks, where the employer can demonstrate that the presence of guardrails would prevent the performance of work.”
OSHA Proposed Standard for Walking-Working Surfaces (May 2010). The proposed standard indicates that guarding is needed on loading docks for heights of 4 feet or more, unless people work an undefined distance away from the edge. But there is an exception. If guardrails are infeasible, work may be done without guardrails if the work is in process, only authorized employees have access, and authorized employees are trained.
ANSI Standard A12.1264.1 Safety Requirements for Workplace Floor, Wall Openings, Stairs + Railings. The American National Standards Institute states that loading docks are an exception for requiring fall protection.
THE BULLETIN: Fall Protection & Workplace Safety on Loading Docks. A one-page review of the rules, regulations and guidelines related to fall prevention and loading dock safety.
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