Fall protection

OSHA's duty starts at a height and an edge. Under 29 CFR 1926.501(b)(1), each employee on a walking or working surface with an unprotected side or edge 6 feet or more above a lower level must be protected by guardrail systems, safety net systems or personal fall arrest systems.

The edge half of that sentence is a defined term. Section 1926.500(b) defines unprotected sides and edges as any side or edge of a walking or working surface, except at entrances to points of access, where there is no wall or guardrail system at least 39 inches high. The surfaces it gives as examples are a floor, a roof, a ramp and a runway, so a roof is named in the definition.

The first of the three systems is also defined there. A guardrail system is “a barrier erected to prevent employees from falling to lower levels.” A guardrail keeps a fall from happening. A personal fall arrest system works the other way round, stopping a worker who has already gone over, and its parts and limits have their own entry.

OSHA writes a separate paragraph for each kind of roof, and both keep the 6-foot trigger. On a steep roof, section 1926.501(b)(11) calls for “guardrail systems with toeboards, safety net systems, or personal fall arrest systems.” The toeboard is the difference from the general rule.

On a low-slope roof, section 1926.501(b)(10) keeps the three systems for employees engaged in roofing activities and adds options built on a warning line. Those options, and where OSHA draws the 4 in 12 line between the two kinds of roof, are set out under low-slope roof.

Subpart M, the part of OSHA's rules these sections sit in, sets requirements for “fall protection in construction workplaces covered under 29 CFR part 1926.” The same section 1926.500(b) defines roofing work as the hoisting, storage, application and removal of roofing materials and equipment. Cleaning is not among the things that definition names.

That leaves a legal question open: whether a particular cleaning job is covered by Part 1926 or by a different part of OSHA's rules. This glossary does not answer it, and it is a question for OSHA or for counsel. What can be said is that the 6-foot rule is the benchmark the roof cleaning trade works to, and that is the only way it is cited here.

The roofing sources use the phrase without citing the federal rule. Eagle Roofing Products, a concrete tile maker, has a 2019 cleaning article whose fall protection line is already quoted in the roof cleaning page's section on who should be on the roof. Its 2020 article says that when a professional is walking a steep-sloped roof, owners should “ensure they utilize a fall restraint apparatus when cleaning and working on your roof.” Fall restraint apparatus is Eagle's own phrase, not one of the three system names in OSHA's rule.

The Tile Roofing Industry Alliance's Roof Maintenance Guide strongly recommends “proper fall protection” when a tile roof is walked, and the recommendation names no tile profile, so it reads the same for a high-profile tile roof as for a low-profile tile roof.

Two questions sit next to this term and have their own answers: whether anyone walks on the roof during a cleaning, and whether a roof can be cleaned from the ground.