SPECIAL POINTS OF INTEREST

SAFETY BULLETIN / October - December 2005

Can there be a painted stripe on the roof for a warning line?
Painted lines are a problem in a snow belt and obviously where aggregate is on the roof. I prefer painted lines for permit required roof access. The raised warning line is a system designed to get the attention of someone backing into an opening or toward an edge. Roofers are notorious for backward walking while unrolling their material and may not see a line painted on the roof. But in some situations, a painted stripe or walk path can be used as fall protection.

Should tool belts be worn under or over full body harnesses?
Raising tools separate from the worker is sometimes safer and easier on the worker. If you must wear both, harnesses go on first. Tool belts should not impede the movement of harness straps during a fall and should not turn into a waist belt that could damage stomach organs in the fall arrest and subsequent suspension.

Is fall protection required for inspections or assessments of roofs?
First, 29 CFR 1926 Subpart M does not require fall protection for those conducting the initial inspection of the roof to determine what work needs to be done. Section 1926.500(a) states, “This subpart sets forth requirements and criteria for fall protection in construction workplaces covered under 29 CFR Part 1926. Exception: The provisions of this subpart do not apply when employees are making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed.” It goes on to state that if inspections are made while construction operations are underway, all employees who are exposed to fall hazards while performing inspections must be protected as required by Subpart M. Exception: The provisions of this subpart do not apply when employees are making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed.” It goes on to state that if inspections are made while construction operations are underway, all employees who are exposed to fall hazards while performing inspections must be protected as required by Subpart M.

Can trades other than roofing, residential, pre-cast erection, or leading edge work use a warning line as fall protection?
Yes, the use of warning lines for all other trades is acceptable when they are set back a minimum of 15 feet from the edge, the warning line meets or exceeds the requirements in 1926.502(f)(2), no work or work-related activity is to take place in the area between the warning line and the edge without the use of conventional fall protection, and the employer effectively implements a work rule prohibiting the employees from going past the warning line without the use of conventional fall protection.