SPECIAL POINTS OF INTEREST

SAFETY BULLETIN / July - September 2006

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The Parapet Wall Dilemma

Matt McCreery, Safety Specialist

Most if not all OSHA standards have some vagueness to exactly what needs to be done or to what specifications one must meet to be fully compliant.  One of the standards that seems to cause the most disagreement and discussion, among roofers, is the parapet walls.  This is because most roofers and foreman tend to believe that a parapet wall of any height is enough to ensure a safe working environment and to be in compliance with OSHA regulations.  This misinformation is to the fault of OSHA as much as anyone for their ambiguity on this matter.  While it is clearly stated that guardrails must be 42 inches plus or minus three inches, and that their accompany mid-rail should be approximately half the distance of the top-rail, the mention of parapet walls in the standard only goes as far to say that a parapet wall may be used as a mid-rail when it meets the minimum 21 inches.

While no mention of a parapet wall that is fully compliant to fall protection issues exists in the OSHA standards, parapet walls should be considered a “guardrail” that meets minimum OSHA standards if its height reaches at least 39 inches from the working surface.  Where does the confusion come in with the typical roofer?  The fact is that a parapet wall that does not reach the minimum requirement of 39 inches is more of a hindrance than it would be if the roof had open edges.  On a typical flat roof “alternative fall protection” is a designated area where warning lines are set at least 6 feet from the roof edge.  This is what is normally used because of ease to set-up and move.  This also allows for roofers working close to the edge to be monitored by a safety monitor who is easily distinguishable from the rest of the crew usually by a bright colored vest.  These “alternative fall protection” methods can be used in conjunction with a short parapet wall however this greatly reduces the work-area and it is especially noticeable on some of the smaller roofs and sections.   In the case of parapet walls that are less than 39 inches a guardrail must be built on-top of the parapet to reach the designated height and to be OSHA compliant.  Most of the time this is not feasible since the construction of these guardrails take considerable more amount of time than the warning line system and can also cause damage to the weatherproofing already installed on the parapet wall. 

Awareness is the key to all safety measures and this particular issue is no different.  Roofing employees, especially the foreman in charge of site safety should be aware that a parapet wall of less than 39 inches does not meet OSHA regulations.  Therefore, the only acceptable answer at this time is to either build or buy a suitable guardrail to install on the existing parapet or use warning lines coupled with the safety monitor to be in compliance.