Commercial Roofing Fall Protection


Fall Protection Options for Commercial Roofing

Screen_Shot_2016-08-23_at_15.37.39Falls are a leading cause of disabling injuries and fatalities in construction, and one of the greatest hazards commercial roofers face every day. To effectively protect workers from these hazards, fall protection must be planned into each job and meet requirements of the building design.

Working on low-slope roofs can be particularly hazardous for construction workers when conventional forms of fall protection are not always an option.




Employers must be aware of the many factors involved in fall protection systems. First, safety-monitoring systems require a competent person. This means s/he has the training or experience to identify hazards or unsafe behaviors and the authority to take action and correct the hazard or at-risk behavior. A safety monitor is responsible for employee safety. S/he must constantly watch for employees backing up in the direction of an unprotected edge or leaning over an edge when they could accomplish work by kneeling. Safety monitors should also direct employees away from the leading edge when their job does not require close proximity to the edge. For this approach to work effectively, companies must spend a great deal of time training safety  monitors on their job responsibilities, and roofers must follow  the orders  of safety  monitors without argument.

Screen_Shot_2016-08-23_at_15.38.03The monitor must also monitor other key requirements. The safety  monitor must be on the same walking and working surface and within  visual sighting distance of the employee being  monitored; the safety  monitor must be close enough  to communicate vernally  with the employee; and the safety  monitor  must have no other responsibilities that could take his/her attention  away from the monitoring function.

The definition of mechanical equipment also has that has great bearing on the use of a safety monitor.  OSHA defines mechanical equipment as "motor- or human-propelled wheeled equipment used for roofing work, except wheelbarrows or mop carts." This includes motorized roof cutters as well as human-propelled equipment such as four-wheel carts, roofing luggers and felt-laying machines. The 1926.502(h)(2) standard  states that mechanical equipment must not be used or stored in areas where safety-monitoring systems are being used to monitor employees engaged  in roofing operations on low-slope roofs. Finally, no employee, other than those engaged in roofing work on low-slope roofs, may be allowed in an area where an employee is being protected by a safety monitoring system.

Warning line systems are often used in conjunction with safety monitoring systems. According to OSHA, a warning line system is "a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, which designates an area in which roofing work may take place without the use of a guardrail, body below, or safety net system to protect employees in the area." Several requirements come into play when implementing a properly designed warning line system:

  • When mechanical equipment is not being used, the warning line must be erected no less than 6ft from the roof edge in any direction.
  • When mechanical equipment is being used, the warning line must be erected no less than 6ft from the roof edge, which is parallel to the direction of mechanical equipment operation, and no less than 10ft perpendicular to the direction of mechanical equipment operation.
  • All points of access, including material handling areas and storage areas, must be connected to the work area by a path formed by two warning lines. When a path is not in use it must be barricaded.
  • The warning line itself must be flagged every 6ft with high visibility material. It must be set 34 to 39 in. above the working surface and it must have a tensile strength of at least 500 lb.
  • The line must be attached to each stanchion in such a way that it will not allow any slack to be pulled through the stanchion itself.
  • Supporting stanchions must resist a horizontal force of at least 16 lb when applied 30 in. above the walking and working surface.

Employees must be properly trained to understand and follow all rules. Frequent problems found with warning line systems are sag in the lines, lines set too close to the roof edge and lack of flagging due to weather exposure or wind. The warning line must be maintained and replaced as needed. A common system used in roofing work is a combination of a warning line system and a safety monitor. The safety monitor is used when employees must perform work outside of the warning line system. However, it is important to remember that mechanical equipment cannot be used in an area protected by a safety monitor.


The construction industry is finally transitioning to use of conventional fall protection on roofing projects. Some larger general contractors no longer use safety monitors or warning lines; these systems are instead being replaced by guardrail systems and personal fall arrest systems or fall restraint systems.

Personal Fall Restraint Systems

Personal fall restraint systems are designed to keep workers on the roof so they cannot fall over the leading edge. Personal fall arrest systems consist of an anchor, a connector or lanyard, and a full body harness. Equipment inspection is necessary and employees must be trained to look for damage such as cuts, burns, sun damage and/ or holes. Any time damage is found, the harness or lanyard must be replaced immediately and the old harness must be destroyed. Another key issue with personal fall arrest systems is the location of the D-ring on the full body harness. The D-ring should be located between the shoulder blades. Employees with shoulder or flexibility issues can use a simple D-ring extender, which makes hooking up easier.

Shock-absorbing lanyards should be worn with the shock pack closest to the D-ring. Remember, a double­ locking snap hook must always be connected to a D-ring. Never hook a snap hook to another snap hook and always use the double-locking type.

Over the past several years, many new anchor systems have been developed and introduced to the market, offering anchor solutions for almost any application.

There are mobile fall arrest carts, which come in various models, including large models designed for up to three employees for fall arrest and two employees for fall restraint. Smaller, more portable models are designed to provide fall arrest or fall restraint for one person. These anchors, when used on an approved substrate, can be moved around the rooftop without penetrating the roof. The only time the roof may be penetrated is if an employee falls and the stop­ ping mechanism is engaged. Other anchors on the market include free­ standing or heavy anchors designed to be set in place, doorjamb anchors and temporary screw-in-place anchors. As with any piece of fall protection equipment, employers must take time to train employees about proper installation and use of these different anchors. If used improperly, the employee's safety is at risk.

A common issue with personal fall arrest systems is the free fall issue and accounting for total fall distance. Simply tying off is not sufficient. Companies must plan and account for free fall, total fall distance and swing fall hazards. Construction standards allow for a maximum of 6ft of free fall. When setting up the personal fall arrest system, consider the clearance to the next lower level. When working 10ft up, 6ft of free fall will not ensure clearance from a lower level. Total fall distance is very important and should be reviewed with any employee using a personal fall arrest system from the anchor point, remember the following requirements: A 6-ft lanyard, 3.5ft of shock absorption and approximately

5ft between the D-ring on the full body harness and the bottom of a worker's feet. A safety factor of at least 3ft should also be added for a total of at least 17.5ft of clearance from the anchor point to the lower level.

Finally, it is important to have a rescue plan. Serious health issues can arise in a matter of minutes when hanging in a harness, not to mention that other health factors may have led to the employee falling. Prompt rescue is a must, and having a plan is a requirement. Ensure that the plan is in place and that employees are trained in rescue procedures prior to using any personal fall arrest system Remember to spend time training employees regarding all personal fall arrest system requirements, including rescue procedures. Once again, this is an active fall protection system that employees need to pay attention to throughout the day.


Guardrails are the next line of defense in commercial roofing operations. Unfortunately, not all buildings have a parapet that is at least 39 in. high, which is the minimum height acceptable for a guardrail. OSHA regulations call for a top rail located between 39 and 45 in. above the walking and working surface. They also require a midrail and a toe board as a best practice for preventing objects from falling and posing hazards for those working below. The guardrail must be able to withstand, without failure, a force of at least 200lb applied within 2 in. of the top edge, in any outward or downward direction, at any point along the top edge.

Guardrails are a passive form of fall protection, meaning that once properly installed, they are a physical barrier designed to keep workers from falling. There is no need for safety monitors because fall hazards are eliminated. Mechanical equipment can be used all the way up to the guardrail, and once the rail is in place there is no need to worry about employees violating fall protection requirements.

In roofing operations, guardrails are often used in combination with other systems such as warning line systems or personal fall arrest systems. Typically, a guardrail is placed in the hoisting area and hot pipe area. As noted, on many projects where the roof detail allows, perimeter rails are set on all exposed edges of the project.

Guardrail systems are often dependent on the type of roof edge to have a suitable anchor location for the uprights. Some of the newer systems on the market will adapt to most any type of roof edge whether it be a gravel stop, cant edge, or parapet. If wire rope is used, it must be at least one-quarter in. thick and must be smooth surfaced. When using wire rope for the guardrail, it must be flagged at least every 6ft with high­ visibility material.

Some issues commercial roofers have with guardrails include roofing installations that extend up and over the parapet or roof edge, as they often do. In these cases, the roof system is often temporarily installed, and roofers must come back to remove the rail and finish the edge detail. Personal fall arrest systems may be used for this activity, but it does add additional labor to the project. The use of guardrails on the perimeter edges of roofing projects is growing and should continue to grow in the future. The key to safely using guardrails is proper training on the use and installation of guardrail systems, including proper selection of fasteners, proper design criteria and following proper  fall protection  protocols while installing  and removing the guardrail system


Rooftops may have penetrations, skylights and roof openings for rooftop units. Such hazards must be addressed. Drain holes, vent stacks and conduit penetrations are found on virtually every rooftop. These openings must be properly covered or be isolated by a guardrail to ensure protection from falls and/or falling objects. Material selection will depend on the size of the opening. If needed, consult a structural engineer to ensure that the cover is sufficient for the loads to which it may be exposed. Remember to properly cover, secure and mark covers with the word hole or cover. All employees should be trained to recognize these hazards, and must always look underneath any pieces of plywood, insulation or other material that may lie on the rooftop. Skylights are considered roof openings and should be properly protected as well. Guardrails covers and other products are available to protect a skylight without removing it. Other options include removing the skylight and installing ply­ wood over the opening. Take roof openings seriously and plan protection into your project.


As with any project, planning safety into commercial roofing projects is a must. Preconstruction reviews of a project and site visits before starting work are the most effective ways to plan safety into your project. Such strategies will ensure that you provide your employees with the tools, training and skills needed to properly protect themselves and their coworkers from fall hazards while performing roofing work.

Brock Hamre, CHST, is the safety director for the Twin Cities Roofing Contractors Association. In this role, Hamre has served as an overall safety and health resource for more than 20 commercial roofing and sheet metal shops, providing safety training and working closely with the Local 96 apprenticeship program.


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