E. “Guardrail systems shall be capable of withstanding, without failure a force of at least 200 pounds (890 N) applied within 1 inch (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge” [29 CFR 1926.502(b)(3)]. OSHA has provided specifications for most commonly used materials that will meet the requirements in Subpart M Appendix B. As previously noted, there are many types of guardrail systems available by many reputable manufacturers, all of whom have tested their systems to meet the OSHA requirements for fall protection.
shall use the Fall Monitor System. System manufacturer guidelines shall always be referenced and followed and by no means are contractors permitted to alter components of a guardrail system. As of January 15, 2022, OSHA violations carry a penalty of up to $14,502 per violation. A Willful or Repeated violation can result in up to $145,027 per violation. A fall protection violation often results in multiple citations and fall protection issues and can be enforced per employee exposed to the fall hazard individually, so the correct materials, set-up, maintenance and following the rules during operations is vital. The ability of roofing contractors to utilize F. “The ends of all top rails and midrails shall not this system not only relieves frustration in the field overhang the terminal posts, except where such from the use of personal fall arrest system ropes and overhang does not constitute a projection hazard” harnesses, it also increases productivity and allows a [29 CFR 1926.502(B)(7)]. Although it may be acceptgreater area of work to be performed or easier pasable to have rails overlap one another at exterior corsage in tight locations. However, this system has a ners, it is prohibited to have them overhang at interior high potential for workers to remove components, corners or where workers have access to the exterior leave individual parts not fully attached and push the side of the structure where the guardrails are set-up. system beyond its limits, resulting in severe injury or death. When this system is being used on a roof, G. “When guardrail systems are used at hoisting all workers in the area shall be trained on the proper areas, a chain, gate or removeable guardrail section set-up, use and restrictions of the system. A fall from shall be placed across the access opening between an elevation of 6 feet or greater is a serious incident guardrail sections when hoisting operations are not taking place” [29 CFR 1926.502(b)(10)]. It is important roofers should avoid at all costs. In 2018, $5.9 billion was paid in compensation cost for falls from elevato note that while the guardrail system is taken down for hoisting operations, employees in that area are no tions, however the actual cost must also consider the indirect cost and the costs of an OSHA penalty. Calculonger protected by a guardrail fall protection syslations made by the National Safety Council estimated tem, therefore they must utilize another form of fall that fatalities at work cost $1,120,000, not including protection such as personal fall arrest. It is also very the value of loss of life or a loved one which cannot be important that employees who remove sections of calculated. the guardrail for hoisting operations, fully replace the Workers exposed to a fall potential of 6 feet or guardrail system and secure them in place when the greater are required to use one of the following for fall hoisting activity has been completed. protection per OSHA standards: safety nets, guardH. “Top rails and midrails shall be at least 1/4-inch rail systems or personal fall arrest systems. When (.06 cm) nominal diameter or thickness to prevent considering the type of fall protection system to be cuts and lacerations. If wire rope is used for top used on your next project, consider not only the cost rails, it shall be flagged at not more than 6-foot (1.8 of the system, but the functionality of the system and m) intervals with high-visibility material” [29 CFR the protection benefits provided to the workers in the 1926.502(b)(9)]. Beyond the importance of the thickfield. Train all workers on the type(s) of fall protection ness of material to be used, it is also noted that when systems being used on the project so that they unwire rope is used, flagging must be present similar derstand how it should appear, how it works and what to that of a warning line system. The wire rope obtheir role in the system is. We need every worker we viously has a much higher tensile strength than the have, every day and want them to go home to their materials permitted for a warning line system and are families the way they left for work in the morning. also designed so that they are capable of withstandFRM ing outward forces with minimal deflection as noted The FRSA Self Insurers Fund (SIF) has professional previously. safety consultants throughout the state of Florida Now that you have an understanding of a guardrail who are willing to provide SIF members with fall system, you may be wondering how this system is protection training as required by OSHA at no addiinstalled in the first place. The guardrail system does tional cost. Not an SIF member? Call today to apply not magically appear on the site when workers get at 800-767-3772 ext. 206 or visit our website at there to work. The fall protection system must be the www.frsasif.com. first agenda item on the project and removal shall be the last agenda item. While the system is being established or taken down, the workers handling the task 18
FLORIDA ROOFING | March 2022