6.4 Hazard Communication, SDS, Silica, Lead & Asbestos Exposure, Power Lines & Heat

Hazard Communication

MIOSHA's Hazard Communication standard for construction (Part 42, combined with the general industry and occupational health versions) follows the federal Globally Harmonized System approach. Roofing employers must:

1. Keep a written hazard communication program that lists the hazardous chemicals on site and explains labels, Safety Data Sheets (SDS), and training.
2. Keep an SDS for each hazardous product readily accessible to workers on every shift. A binder in the truck or an electronic device works if workers can reach it.
3. Make sure containers are labeled, including secondary containers such as a squeeze bottle of cleaner or a bucket of primer.
4. Train workers before they are exposed and whenever a new hazard is introduced.

Common roofing chemicals include asphalt primers and cutback cements, solvent-based EPDM and TPO adhesives and seam primers, TPO and PVC cleaners, polyurethane foam adhesives, silicone and acrylic coatings, spray foam, and propane.

Reading an SDS

A GHS label shows the product identifier, signal word, hazard statements, pictograms, precautionary statements, and supplier information.

Respirable Crystalline Silica (MIOSHA Part 690)

Cutting or grinding concrete or clay tile, slate, fiber-cement shingles or panels, and masonry (for example, cutting a chimney reglet) releases respirable crystalline silica. Part 690 sets an action level of 25 µg/m³ and a permissible exposure limit of 50 µg/m³, both as 8-hour time-weighted averages. Employers may follow Table 1 instead of measuring exposure. Table 1 examples:

• Handheld power saws on silica materials: an integrated water delivery system that continuously feeds water to the blade. Outdoors, no respirator is needed for 4 hours or less per shift, and an APF 10 respirator is needed beyond 4 hours.
• Handheld saws for fiber-cement board (blade 8 inches or less): outdoors only, with a dust collection system and the tool manufacturer's recommended airflow, and no respirator required.
• Tuckpointing and grinding: a shroud with a HEPA-filtered vacuum, plus the listed respirator.

Dry cutting tile while wearing a paper mask does not comply.

Lead and Asbestos on Tear-Offs

• Lead (Part 603): the action level is 30 µg/m³ and the PEL is 50 µg/m³. Disturbing painted trim on pre-1978 homes also triggers the EPA lead-safe rules (Section 2.3).
• Asbestos (Part 602): removing asbestos roofing is Class II work. Keep material intact where feasible, use wet methods when it is not intact, never drop or throw it, and lower it by hand, a covered dust-tight chute, a crane, or a hoist by the end of the shift (Section 2.3).
• Coal tar pitch in old built-up roofs is a skin and eye irritant and a carcinogen. Use the SDS controls and PPE during removal.

Overhead Power Lines

Electrocution is one of the leading causes of death in construction, and roofers handle long metal: ladders, drip edge, valley metal, and gutters. MIOSHA sets these distances:

Assume every line is energized, including the service drop to the house, unless the utility confirms otherwise. Ask the utility to de-energize the line or install insulating covers before working near it.

Heat and Cold Stress

MIOSHA has no specific heat-illness standard. Employers still have a general duty under the MIOSHA Act to protect workers from recognized hazards. For roofing, reasonable practices include:

• plenty of cool drinking water, with workers encouraged to drink often;
• rest breaks in shade, and scheduling heavy tear-off for cooler hours;
• acclimatization for new and returning workers, who should work shorter periods at first;
• training on the signs of heat exhaustion (heavy sweating, dizziness, nausea) and heat stroke (confusion, collapse, very high body temperature). Heat stroke is an emergency: call 911 and cool the worker immediately.

In cold weather, frost and ice make underlayment slippery. Some self-adhered products will not bond below their minimum temperature, and cold stiffens shingles. Check the deck before mounting the roof, and dress workers for wind chill.