6.2 Guardrails, Safety Nets, Warning Lines, Safety Monitors, Covers & Fall Protection Plans

Guardrail Systems (1926.502(b))

On steep roofs, guardrails must have toeboards (1926.501(b)(11)). When materials are piled higher than a toeboard, add paneling or screening high enough to stop them falling over. Remember MIOSHA's Michigan-specific storage rule: while roofing work is performed, materials and equipment may not be stored within 6 feet of a roof edge unless guardrails are erected (R 408.40810(7)).

Safety Nets (1926.502(c))

Nets are installed as close as practicable under the work, and never more than 30 feet below it. They must extend outward from the outermost edge of the working surface:

Nets are drop-tested with a 400-pound bag of sand after installation, after relocation or major repair, and every 6 months if left in place. They are inspected at least weekly, and debris is removed before the next shift. Mesh openings may not exceed 36 square inches or 6 inches on a side, and border rope must be at least 5,000 pounds.

Warning Lines on Low-Slope Roofs (1926.502(f))

Warning lines are allowed only for roofing work on low-slope roofs (4:12 or less), combined with another system or a safety monitor as 1926.501(b)(10) allows.

• Erect the line around all sides of the work area, at least 6 feet from the edge. Where mechanical equipment is used, keep it at least 6 feet from an edge parallel to the equipment's direction of travel and at least 10 feet from an edge perpendicular to it.
• The rope, wire, or chain is flagged at least every 6 feet with high-visibility material. Its lowest point, including sag, is 34 to 39 inches above the surface.
• Stanchions must resist a 16-pound horizontal force applied 30 inches up without tipping. The line must have a tensile strength of at least 500 pounds.

Work inside the warning line needs no other protection. Work between the line and the edge needs one of the combinations in (b)(10).

Safety Monitoring (1926.502(h))

A safety monitor is a competent person designated to watch other workers. The monitor:

• recognizes fall hazards and warns workers who seem unaware of them or are acting unsafely;
• is on the same walking surface, within visual sighting distance and close enough to communicate orally;
• has no other duties that distract from monitoring.

A monitor alone is allowed only on low-slope roofs 50 feet or less wide. On wider roofs, the monitor must be combined with a warning line. Mechanical equipment may not be used or stored where safety monitoring is the protection. No one other than workers doing roofing on the low-slope roof, or covered by a fall protection plan, may be in the monitored area.

Holes, Skylights, and Covers (1926.501(b)(4) and 1926.502(i))

PSI's outline specifically lists "covering skylights and other openings in roofs for fall protection." Workers must be protected from falling through holes, including skylights, more than 6 feet above lower levels. The options are personal fall arrest, covers, or guardrails around the opening. Workers must also be protected from tripping into holes, and from objects falling through them.

Covers must:

1. support at least twice the weight of the workers, equipment, and materials that may be on them at one time. Covers in roadways must support twice the largest axle load expected;
2. be secured against displacement by wind, equipment, or workers;
3. be color-coded or marked "HOLE" or "COVER."

A skylight lens or dome is not a cover. Screen it, rail it, or cover it with secured, marked plywood of adequate strength. When the deck is opened during tear-off, such as for chimney removal, treat the hole the same way.

Falling Objects (1926.501(c) and 1926.502(j))

Protect people below with toeboards, screens, or guardrails, canopies, or by barricading the area underneath and keeping people out (Section 6.5). Keep tools and bundles away from edges. Workers below must wear head protection.

Fall Protection Plans and Controlled Access Zones (1926.502(k) and (g))

A residential employer may use a written fall protection plan only after showing that guardrails, nets, and personal fall arrest are infeasible or would create a greater hazard. Cost and inconvenience are not reasons. The plan must:

• be prepared by a qualified person for the specific site and kept up to date;
• be kept at the job site, with changes approved by a qualified person;
• be implemented under the supervision of a competent person;
• state why conventional systems cannot be used and what other measures reduce the hazard, such as safety monitors or controlled access zones;
• identify each worker covered, and be reviewed and changed if anyone falls or has a near miss.

A controlled access zone limits the area to authorized workers. When control lines are used, they are placed 6 to 25 feet from the unprotected edge.

Choosing the Right System