STEEP-SLOPE ROOFTOP PV SAFETY: MORE TO CONSIDER · • ANSI B20.1-1957 is referenced in the OSHA regulation for operation, inspection and maintenance of a conveyor • May be covered

STEEP-SLOPE ROOFTOP PV SAFETY: MORE TO CONSIDER

presented by:

Harry Dietz Director of Enterprise Risk Management

National Roofing Contractors Association (NRCA) and

John Schehl CAE, RRC Executive Director

Roof Integrated Solar Energy (RISE)

IREC Webinar March 25, 2015

Copyright © 2015 Roof Integrated Solar Energy

Program Objectives

Recognize topics to be addressed in a safety training curriculum

Identify hazards specific to steep-slope PV installations

Apply and interpret OSHA regulations as they relate to specific hazards

Find industry safety training resources

After completing this program, attendees will be able to:


OSHA Standards • OSHA develops and enforces standards that

employers must follow - 29 CFR 1926 Construction Industry Regulations - 29 CFR 1910 General Industry Regulations • Where OSHA does not have standards,

employers are responsible for following the OSH Act's General Duty Clause.

Each employer "shall furnish . . . a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to

employees."


OSHA Approved State Plans 27 states currently operate state plans Alaska Arizona California Connecticut Hawaii Illinois Indiana Iowa Kentucky Maryland Michigan Minnesota Nevada New Mexico New Jersey New York North Carolina Oregon Puerto Rico South Carolina Tennessee Utah Vermont Virgin Islands Virginia Washington Wyoming

OSHA Training Requirements • A broad employer responsibility to

train workers is set out in 1926.21(b)

• Specific training is a component of many of the construction subparts

• Training records are required

• Retraining must be done as necessary

Audience poll

OSHA Standards

Topics We Will Review


Subpart M: Fall protection, as they apply to rooftop PV work Subpart N and CC: Cranes, conveyors and hoists Subpart X: Ladders and stairways

Subpart L: Scaffolding

In 2013, there were 796 fatal work injuries in construction― 294 from falls

Subpart M: Fall Protection


1926.500 (b) Definitions: • OSHA does NOT differentiate using “residential” or “commercial” • Steep-slope roof = a roof having a slope greater than 4 in 12 (vertical

to horizontal) • Low-slope roof = a roof having a slope less than or equal to 4 in 12

(vertical to horizontal) Copyright © 2014 Roof Integrated Solar Energy

Steep-slope commercial Low-slope residential

Topics typically included in construction industry fall protection training include standards relating to fall protection systems, including:

• Guard rails • Safety nets • Personal fall arrest (PFA) • Warning line systems and safety monitors


Guardrail system Safety net system PFA system Warning line and safety monitor system

http://www.bluewater-mfg.com/images/Kwik-Stand0001_L.jpg

• Definition: A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge. They contain an area where roofing work may take place without fall protection systems. 1926.500 (b)

• Warning lines always require using additional fall protection systems: Guard rails Safety nets PFAs Safety monitor

Warning Lines

Federal Letters of Interpretation (LOIs) relating to use of warning line systems by trades other than roofing work. Issue: Interpreting LOIs for a specific project and location

http://www.bluewater-mfg.com/images/Kwik-Stand0001_L.jpg

Criteria for Safety Monitors

• be a competent person

• be at same level

• be within sight

• be able to communicate

• not have other responsibilities that could distract from monitoring

Monitor’s function is to warn an employee when it appears the employee is unaware of a fall hazard or is acting in an unsafe manner. A safety monitor must:

Topics that also should be included in construction industry fall protection training include: - PFA anchors, locations and swing fall radius - Fall rescue plans and suspension trauma - Holes and skylights - Fall protection exception


Common Roof Anchors

Standing Seam Roof

Locating Roof Anchors— Residential Guidelines

• Before starting construction, plan where to install anchors

• Locate at roof peak if possible and at least 6 feet from exposed roof edge

• DO NOT install on unsupported roof structures (e.g., eaves or gable overhangs)

• Hip roofs need anchor at each hip face

Swing Fall Hazards

Gable End Swing Fall Swing Fall Hazard

the “… employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.”

29 CFR 1926.502(d)(20)

OSHA Standard: Fall Rescue

Harness-induced Injury or Death

(a.k.a. orthostatic intolerance, orthostatic incompetence

or orthostatic shock)

The clock starts ticking immediately once a fall occurs. Some researchers say death can occur after a short time suspended in a harness!

Suspension Trauma

• Can occur when legs don’t move and legs are lower than the heart

• May be complicated by other injuries from a fall such as a neck trauma, broken bones, cuts, etc.

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Fall Rescue Plan

Rescue should be addressed in a company safety program as part of its fall protection plan

OSHA's 1926 Subpart M envisions post-fall rescue as a preplanned event

Workers should be trained in available rescue equipment and specific techniques, along with the hazards of a rescue operation

Rescue

Two basic elements of rescue: Delay orthostatic shock

Bring the fallen worker to a

supporting surface

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Holes and Skylights

• Holes (two inches or larger) and skylights

(6 feet or more above a lower level)

– Personal fall arrest systems – Guardrails – Covers

• Also protect employees from objects falling through holes or skylights

• Capable of supporting 2X weight of potential employees, materials and equipment

• Secured

• Color coded or marked “Hole” or “Cover”

Criteria for Hole Covers

This hole needs a guardrail or strong cover

Exception to Subpart M

The fall protection requirements of Subpart M don’t apply when workers are inspecting, investigating or assessing a workplace: Before the work has started, OR After the work has been completed

Equipment covered: OSHA crane standard applies to “power-

operated equipment, when used in construction, that can hoist, lower and horizontally move a suspended load.” 1926.1400(a)

Such equipment includes: • Crawler cranes • Mobile cranes • Service/mechanic trucks with a hoisting device (except

when used to maintain & repair equipment • Boom truck cranes (with an important exception) • Tower cranes

Subpart CC and Subpart N Cranes, Conveyors and Hoists

Specific exclusions- Knuckle-boom truck cranes

1926.1400(c)(17) Equipment • “Articulating/knuckle boom truck cranes” • Must be equipped with automatic overload prevention device Operations • Delivery from truck to ground, or • Delivery to structure using a fork cradle Material • Sheet goods (drywall, plywood) • Packaged material (PV panels, BOS items, shingles)

Crane Operator Certification/qualification

§1926.1427 “…employer must ensure that, prior to operating any equipment covered under subpart CC…the operator is qualified or certified to operate the equipment…” by one of the following: – A state or other government licensing entity – An accredited crane operator testing organization – An audited employer program – The U.S. military A new proposed rule has been issued related to certification based on "type and capacity."

Licensed by a State or Local Government Agency

In state or local jurisdictions with crane operator licensing rules

• operators must be licensed

under the local rules • operators-in-training may

operate equipment according to pre-qualification/certification rules

Signal Persons OSHA requires a signal person if: • Point of operation (load travel or

load placement) is not in full view of operator

• During crane travel, the direction of travel is obstructed

• The operator or person handling the load determines one is needed because of site specific safety concerns

Qualified Riggers

A qualified rigger is one who has knowledge, training, experience or possesses a degree or certification and has demonstrated an ability to solve problems related to rigging.

A qualified rigger is required in most instances when workers are within the “fall zone”

Conveyors and Hoists

• Covered under 29 CFR §1926.555, Subpart N

• OSHA requires emergency stop switches at the operator station or the motor

• ANSI B20.1-1957 is referenced in the OSHA regulation for operation, inspection and maintenance of a conveyor

• May be covered under Subpart CC but also in Subpart N at 29 CFR 1926.552-554

• Critical element is the load capacity of the hoist in determining which provisions of Subpart CC apply—2,000 pounds or less

• Only specific sections of CC apply—see 1926.1441

Subpart X: Stairways and Ladders

Non-self-supporting ladders, OSHA’s term for extension ladders Ladder angle: Position at an angle such that the horizontal distance from the top support to the foot of the ladder is 1/4 the working length of the ladder

Ladder rail extension: When using a portable ladder for access to an upper landing surface, the side rails must extend at least 3 feet above the upper landing surface—the ladder must be tied-off and a grab rail provided if the 3-foot extension cannot be achieved. 29CFR1926.1053(b)(1)


Climbing a Ladder: • Face the ladder when going up or

down

• Use at least one hand to grab the ladder when going up or down

• Do not carry any object or load that could cause you to lose balance 29 CFR 1926 1053(b) (20), (21) and (22)


At heights greater than 10 feet, the fall-protection requirement for workers on scaffolds is different than the general construction requirement at 6 feet or greater.

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29CFR1926.451(g)(1)



Scaffold Fall-protection Rule Applies To: • Tube and coupler scaffolds • Ladder jack scaffolds • Pump jack scaffolds • Chicken ladder • Roofing slide guards

Scaffold fall protection options: • Tube and coupler scaffolds: Guardrails or

PFAs • Ladder jack scaffolds: PFAs only • Pump jack scaffolds: Guardrails or PFAs • Chicken ladder: Guardrails, PFAs or ¾-inch

grab line or handhold next to chicken ladder

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Where to get OSHA standards

• CD-ROM subscription through U.S. Government Printing Office (GPO)

• Federal Register in public libraries or at GPO web site

• Code of Federal Regulations (CFR) in public libraries, through GPO and other sources

• OSHA web site - OSHA standards, interpretations, directives (www.osha.gov)

• Private publishers i.e. Mancomm

http://www.osha.gov/

Where to get safety training materials

• OSHA web site – training materials at https://www.osha.gov/dte/grant_materials/

• OSHA website—training institutes at

https://www.osha.gov/dte/edcenters/index.html

• NRCA website—education section at

www.nrca.net • RISE website—resources listed in the CSRP

candidate handbook

THANK YOU!

What are your questions?


Documents

STEEP-SLOPE ROOFTOP PV SAFETY: MORE TO CONSIDER · • ANSI B20.1-1957 is referenced in the OSHA regulation for operation, inspection and maintenance of a conveyor • May be covered