OSHA Fall Protection Guidelines

OSHA Fall Protection Guidelines

By Jim Brewer, Owner, Rooftop Safety USA

In 2023, the Occupational Safety and Health Administration (OSHA) issued a National Emphasis Program (NEP) on fall protection to step up prevention and enforcement activities. The NEP had a target list of 10 industries of interest, and “chimney cleaning” was number eight on the list. Through my safety work with chimney service companies, I am aware of many inspections, and most of them resulted in fines. The fine for not using fall protection is $16,131, but OSHA does reduce that amount for good faith efforts and company size. Most companies in the chimney service industry qualify for sized based reductions.

Your best defense against OSHA fines is a robust safety program where employees are provided the equipment they need to work safely, along with training to know when and how to use the equipment. Another component of the program should include setting clear expectations for safety procedures, along with monitoring and enforcement of those expectations. Remember, most employees “do what you inspect, not what you expect,” so monitoring and enforcement are an important component.

In December 2023, the National Chimney Sweep Guild (NCSG) reached an agreement with OSHA concerning fall protection requirements for companies in the chimney service industry. You can (and should) download a copy of the full 37-page agreement on the NCSG website (ncsg.org). The agreement provides several options for chimney service companies that previously have never been permitted by OSHA including:

• Use of trees, chimneys, and vehicles as anchors

• Definition and use of fall protection aid for products like the Goat and the RidgePro

• Definition and use of nonpenetrating roof anchor

• Use of roof ladders

• Exemption from fall protection during inspections

• Use of ladders on roofs to access chimney top

Prior to using these new options, a company must have in place:

• A documented Safety Program for Rooftop Work

• Provide equipment & training to work in accordance with the Safety Program

• A procedure for assessing the hazards at each worksite and creating a Fall Prevention Plan for the worksite

Hazard Assessment

Each job should begin with a Hazard Assessment, conducted by a Competent Person. The Hazard Assessment should consider the following:

• Weather: Wind, rain, snow moisture, temperature

• Roof Evaluation: Condition, pitch, composition, anything covering (moss, snow, ice, leaves), work location, access to the roof and work area

• Site Hazards: Power lines, sloping terrain, skylights

• Nature of Work: Time required, materials and ladders required, safely transporting materials to worksite

You should also identify roof access points and potential anchors during the Hazard Assessment.

Fall Prevention Plan

A written, site-specific Fall Prevention Plan must be completed by a Competent or Qualified Person before work begins. A flexible, generic template may be used.

Your plan should include:

• Selection of location and method to access the roof

• Selection of fall protection measures

• Selection of necessary personal protective equipment (PPE) (shoes, harness climbing helmet, etc.)

Keep in mind that you must establish your Safety Program before using the newly authorized OSHA options and that their use is voluntary. However, if you decide not to use the new options, you are still required to follow all existing OSHA requirements for fall protection. ■

Jim Brewer is the owner of Rooftop Safety USA, which provides safety training and equipment to the chimney service industry.

You can reach Jim by visiting RooftopSafetyUSA.com, emailing jim@RooftopSafetyUSA.com, or calling (757) 435-0407.