This being Fall Prevention Week with OSHA I thought I would lay some things out about the dilemma facing many residential roofing employers. The dilemma is how to get employees to utilize fall protection?
The roofing industry will need to come together collectively and rethink their approach to fall protection. The current labor pool in the state of Florida makes it increasingly difficult to find qualified workers, workers willing to learn, and workers who are willing to put safety over money. The fact of the matter is that many of these companies “pay by the piece”. The labor pool that is working under this type of pay structure are usually poorly educated and have developed the paradigm that traditional Fall Arrest Systems slow them down and are more of hindrances to production. In many cases this is true only because they a poorly trained and rarely supervised. There usually is no real method to the tear off phase, dry in, or retile. It is a free for all and when they do use the traditional fall protection there is no method to the madness. Ropes become intertwined and pile up in a nest of knots tangled in the tile bundles on the roof. This occurs only because most residential roofers I have met refuse to put a competent person on the job site to supervise.
Virtually every roofing employee I have interviewed over the years as a compliance officer freely admitted that they were the ones who made the decision to work unprotected rather than their employer.
Many roofing companies are under constant threat of loosing good qualified roofers as a result of their zero-tolerance policy of 100% tie off. Fearing that whole crews of employees simply walk away to the roofers who are not fully enforcing the rules, or not supervising the work. In fact, that is exactly what is happening in Florida, but no one is willing to publicly admit it.
US Bureau of Labor Statistics (2016) predicted that the employment rate in the roofing industry will grow 11 percent (i.e., 16,200 more employment) by 2026. This is faster than the average of all occupations (US Bureau of Labor Statistics 2019). Especially replacement and repair of roofs and the installation of new roofs will create demand for roofers.
A total of 20,498 occupational fatalities occurred in the construction industry from 1992-2009. Of these deaths, nearly one-third – 6,591 – were attributed to fall injuries, with 2,163 fatalities resulting from roof falls. Citing the U.S. Bureau of Labor Statistics, the study points out that falls account for 76 percent of fatalities in the roofing industry, and workers in the roofing industry are three times more likely to experience fatal work-related injuries than other construction workers.
Some factors that contribute to falls from roofs:
• Worker inexperience or lack of training
• No fall protection program or a personal fall arrest system
• No personal fall protection used
• Incorrect fall arrest system anchorage method
• Lack of fall arrest system lanyard connection point
• Incorrect working length of fall arrest system lifeline
• Working alone when working at elevations
• Working during inclement weather (e.g., wind, rain)
Never mind the fact that the roofing industry is the bread and butter of OSHA’s internal quota system. Each Area office is required to obtain a certain amount of inspections per year. Even though the agency would deny they have quotas, I know from my own experience they do. The Area Directors and Assistant Area Directors as well as the compliance officer’s annual performance reviews are subject to scrutiny if they do not make goal. Each fiscal year the Regional Offices pass down the required number of inspection per year to the area office and at least weekly in some regions the Area Directors and Assistant Area Directors are called to the carpet and pressured to come up with plans to meet goal. Roofers being highly visible from the road are prime targets for even the lowest preforming compliance officer and many employers make it all too easy for them.
The obvious answer to would be to end the current method of payrolling these workers, but we all know the competition amongst the roofing companies just will not allow that to happen.
There are alternatives on the market and every year there is something new being introduced.
According to OSHA standard 1926.501(b)(13), residential construction laborers working at least 6 feet above lower levels must be protected by fall protection such as guardrails, safety nets or personal fall arrest systems. However, a compliance directive (STD 03-00-001) that went into effect in 1999 allowed residential construction companies to use specific alternative methods of fall protection. It did not require the employer to have a written, site-specific plan or provide evidence that conventional protections were infeasible or a greater hazard.
That directive was canceled late last year when OSHA announced a new compliance directive in the Dec. 22 Federal Register. Under the new directive (STD 03-11-002), employers wishing to use alternative fall protection measures in residential construction must meet all requirements in 1926.501(b)(13) and 1926.502(k). Additionally, fall protection plans used to comply with those standards must be site-specific and written out.
What are the alternatives? There are several, let’s look at two companies:
Arco Building systems has a whole list of alternative products that are economical, OSHA compliant, and user friendly. https://www.acrobuildingsystems.com/parts/Safety-Guardrail-Systems-c41249130 .Their line of products is impressive and if your serious about the safety of your employees you need to check them out. A product line that ranges from fixed roof brackets (roof jacks) and adjustable roofing brackets, to top-of-the-line safety guardrail systems and wall scaffolding systems.
According to OSHA’s Website: In general, it is better to use fall prevention systems, such as guardrails, than fall protection systems, such as safety nets or fall arrest devices, because they provide more positive safety means.
Recently I was sent a brochure from a company called i2k Airpad™ https://i2kairpad.com/fall-protection/ . They are selling a line of products that are described as safe landing systems. The inflatable fall arrest device as described in the brochure would be evaluated by seasoned OSHA compliance officer by using the fall arrest netting criteria. If this device meets 1926.502(c) standard and prevents the victim from hitting the ground. OSHA would consider the properly installed and maintained inflatable "Protection Safety Device" as meeting the intent of the standard and could be used for fall protection whenever nets are allowed by the standard. Essentially in layman’s terms they are consider nets and are regulated as such when it comes to compliance. A letter of interpretation was issued in 1995 see the link below:
So you see there are alternatives!
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