As a roofer there is no greater risk than falling off of a roof and getting injured, or even killed. That is why roofing contractors are required to provide their employees with fall protection that is consistent to safety standards set by the Occupational Safety and Health Administration (“OSHA”). For over 15 years OSHA has been very liberal in accommodating the roofing contractor with a degree of latitude which will effectuate both worker safety and efficient production on residential construction jobs. However, it looks as though things will be taking a turn because safety is going to trump the efficiency and productivity of residential construction.
Effective June 16, 2011 the OSHA standard for fall protection will be strictly enforced and effectively enhances fall protection requirements by rescinding a directive that accorded latitude to contractors in instances where complying with fall protection regulations was burdensome, and where contractors could demonstrate “…that it is infeasible or creates a greater hazard to use these systems.” This exception did not mean that a roofing contractor could simply not use any fall protection at all, but rather the employer was required to develop and implement a fall protection plan that met other OSHA standards which ensured the safety of the employee.
For anyone who has never attempted to navigate a roof with a lanyard attached to your back, the process of roofing becomes onerous, burdensome, and very slow because the rope, or lanyard which is anchored at the top of the roof restricts your movement and becomes tangled in roofing jacks, slide rails, and even your feet For the past 15 years roofers were able to opt-out of wearing the personal fall arrest system by installing a guardrail system at the gutter line of the roof, and thereafter utilizing slide-rails every 6 feet up the slope of the roof. This system has proven to be an effective fall stop protection devise that enabled roofers to navigate roofs in a safe and free manner, thereby allowing them to efficiently work without becoming entangled. However, effective June 16, 2011 roofers will be required to implement an additional railing system along all gable-ends and/or adjacent edges – a system that is simply not practical to install – and which would have to be installed and removed multiple times on any given roofing job. As such, the personal fall arrest system will likely be the most popular means of compliance with the rigid OSHA fall stop regulations.
Needless to say, any time that production is slowed down comes the probability of an increase in cost and prices across the board, including that for the consumer. It is my estimation that the rescission of the exception to full compliance will inevitably drive up roofing costs for homeowners. The reason for this is that unlike the majority of construction trades, most roofers are paid by piecework. In other words, roofers get paid based upon the amount of pieces they install, including shingles, flashing’s, vents, and other components of the roofing system. In the retro-roofing market roofers are also paid piece work for tearing off the old roof – a task that is a nightmare to accomplish with a rope dangling and tangling in all the debris.
What originates as a plan to help protect roofers is ultimately going to slow down roofing production and drive up residential roofing construction costs. In the end consumers/homeowners are the one’s who are going to be stiffed by yet another act of government regulation. The sad part about this whole unfounded “enforcement” practice is that the numbers of injuries and deaths of roofers do not justify such a drastic and rigid implementation for safety by OSHA without allowing some safe leeway.