Fall Protection on Residential Construction Projects Expert Article

Fall protection methods used in residential construction can differ from those used in commercial construction. In this article, Civil Engineer & Construction Safety Expert, Gregory Pestine, explores fall protection on residential construction projects by examining a variety of fact patterns borrowed from litigation.

Investigating Falls from Residential Construction Projects

OSHA addresses fall protection for employees performing residential construction in 1926.501(b)(13). The workers most commonly exposed to fall hazards of 6 feet or more are typically those framing the roof or installing roofing materials.

Each employee engaged in residential construction activities 6 feet or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of § 1926.502.

Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall plan which complies with § 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

The three methods of protection presented above are discussed below:

• Guardrail systems: Guardrails are required to be able to resist a minimum 200 lb. loading and are approximately 42 inches in height. There are many pre-engineered guardrail systems that can suffice for fall protection on low-sloped roofs around roof edges and openings which include built-in heavy bases. On steep-sloped residential roofs, guardrail systems are generally not practical or typically utilized.
• Safety net systems: Safety nets have their place but are also generally not practical or typically utilized in residential construction fall protection. They do have the added benefit of preventing debris from falling onto persons and property below.
• Personal Fall Arrest Systems (PFAS): A personal fall arrest system does not prevent a fall, but it allows a worker who has fallen to remain suspended until he or she can be rescued. The system typically includes a body harness that is tethered to an anchor point or lifeline which is secured to the building’s structure. There can be instances where appropriate tie-off points on a residential roof are unavailable until the roof structure is completely framed.

Additional Roof Fall Protection Methods

Other methods of providing fall protection on residential roofs involve warning line systems or working off a stable platform. These methods could include:

Warning Line Systems

For roofing work on low-sloped roofs (not including framing or decking work), OSHA allows the use of warning lines or safety monitoring systems or some combination of these and other systems.

OSHA defines a low-sloped roof as one having a pitch less than 4:12 or four inches of rise for every 12 inches of horizontal distance. Low-sloped roofs are typically utilized in commercial settings such as on the roofs of factories, warehouses, and office and hotel towers.

A warning line is a highly visible line approximately 36” high and placed at least 6 feet from the edge of the roof. When a warning line system is used, the employer must assign a person whose sole responsibility is monitoring safety. This individual must be competent in fall protection hazards and have the authority to issue warnings to all workers in the area.

Ladders

Both stepladders and extension ladders can be used to access elevated work areas for roof framers. Workers are required to descend the ladder prior to moving it to another location.

This additional time and effort make ladders a less desirable means of fall protection for residential framers. Roofers can use ladders to access the roof but need additional fall protection once they are on the roof.

Rolling Scaffolds

Rolling scaffolds can be used by framers to construct the roof structure. Railings are required if over 10 feet high and outriggers may be required to widen the base of the scaffolding above certain heights to provide lateral stability.

Aerial & Scissor Lifts

Both aerial lifts and scissor lifts are safe working platforms for residential roof framing. Both must have guardrail systems. Aerial lifts also require the workers to have a PFAS tied off to the basket of the lift. Both have the added benefit of being able to hoist small amounts of material within their basket.

Case Examples

The following case examples involved falls from residential roofs and falls from roof framing.

Owner Acting as GC, No Fall Protection Provided

An owner of a residential duplex which was used as rental property employed a handyman to do various tasks, including removing the cedar shakes from a portion of the property.

The owner controlled and supervised the means and methods of the work and did not provide any means of fall protection to the worker. The worker slipped and fell to the ground while scraping the cedar shakes.

Unapproved, Ineffective Fall Protection

In an effort to return a hammer which had fallen to the ground, a carpenter climbed out of a framed dormer window to hand the hammer to a carpenter on the roof. In doing so, without fall protection, he slipped on ice and fell to the ground.

The contractor had installed flat 2x4’s, commonly called a “chicken ramp” to assist the workers in climbing up and down the roof. A chicken ramp is not recognized as a means of fall protection by OSHA.

Toeboards Improperly Relied Upon as Fall Protection

A roofer was receiving bundles of shingles on an 8:12 pitched roof while standing on ice and water shield which had been installed over the roof sheathing. He slipped on the wet surface and fell to the ground.

His crew had been relying on vertical “toeboards” which are also permitted in order assist in climbing the roof, but are not considered to be part of a fall protection system.

Use of Non-Load Bearing Surface as Work Surface

While framing a roof, a carpenter accessed the work area between roof trusses by use of a stepladder. He then stepped off the ladder and onto the bottom cord of a roof truss.

Unless the trusses are designed for attic storage space, the bottom cords are typically not able to support heavy point loads (although they can withstand the tension created by the dead load and snow load from above).

The bottom cord cracked under the weight of the carpenter, and he fell to the ground. In this case, the worker should not have relied on the truss cord for support but should have remained on the ladder or used another means of accessing the needed elevation.

Site-Specific Fall Protection Plans

If an employer believes conventional fall protection equipment is infeasible for use on their project and can demonstrate that those methods are not feasible or would create a greater hazard, and does not use ladders, scaffolds or lifts, the employer must develop a site-specific fall protection plan in accordance with 1926.502(k). However, it is typically a very high bar for an employer to be able to prove that fall protection is infeasible or creates a greater hazard.

Construction Safety Investigations

The Construction Safety experts at Robson Forensic have worked at every level within the industry, from bricklayer on residential projects to project manager on multi-prime worksites. Our experts have done the work central to your case and can testify regarding the hazards, risks, and responsibilities in the construction industry.

Submit an inquiry or call us at 800.813.6736 to discuss your case with an expert.

Featured Expert

Gregory H. Pestine, P.E.

Civil Engineer & Construction Safety Expert

With over 40 years of experience in the construction industry, Greg has worked on a wide variety of projects, in many different roles. As a superintendent, quality control manager, and resident… read more.