First, do OSHA regulations apply to you, and does it matter?
You may want to check with your local safety authority, but generally, OSHA (or your State's version) is charged with the daunting task of inspiring employers to provide a safe working environment. They do this by creating regulations pertaining to gear, training requirements and hazards that employees may encounter. They enforce these regulations by issuing citations and fines to employers. It may be possible that repeat failures by an employer may lead to jail time, however I have not yet witnessed this occurrence.
Keep in mind, that just because you or your employees are in compliance with OSHA regulations, that does not necessarily mean that you are safe. For example, OSHA requires fall protection for working at heights over 6 feet, yet has no fall protection requirement for climbing up and down a 40 foot access ladder, and they seem to give you a free pass for roof inspections entirely, yet gravity still is diligently at work. They have regulations about the labels on ladders being in great condition (however many roofers cannot read English and in 30 years I've never seen a label written in Spanish). They have good regulations about the ladder extending 3 feet past the roof eve, yet nothing about tieing off the bottom of the ladder so it cannot slide out from beneath you.
Basically, we try to apply OSHA regulations as minimum standards of working safely. When we can improve a team member's safety by deviating from the normal standards (such as utilizing sternal fall arrest rings with a site-specific fall protection plan rather than dorsal fall arrest rings shown in the top photo) then we do so. The sternal fall arrest ring use is typical for tower climbers and rope access workers but is still unusual in the construction industry. If you are an employer, be sure to implement a Site Specific Safety Plan that explains why you are utilizing 1910.140(c)(22) and deviating from the standard 1926.501(b)(13) with your own policy, then stick to it.
If you are an employer, yes OSHA applies to you.
If you are an employee, yes OSHA applies to you via your employer. Unsafe actions, simply not wearing eye protection, or not using fall protection (even though it's a 4:12 pitch roof, may cost your employer $13,000 or much, much more. So, don't make problems for your boss unless you want to be unemployed.
Sole proprietor, probably not.
Small family business with only family members employed, perhaps not.
DIY'r/Homeowner, no.
OSHA officer off the clock at home, no.
Small LLC comprised of member-owners only, probably not.
Some realistic side notes:
Many roofing company employers that we've met send their employees to an OSHA 10 class, or OSHA 30 class. Generally, they do this in order to "check a box", hoping that this is treated as "training", hoping their employees learn what it takes to have safe working conditions, and hoping to avoid fines later during uncomfortable OSHA encounters. We believe it is absolutely critical to learn how to identify hazards, and the class can do some of that, but it will not teach the roofer or solar installer the most important things they need to know.
The roof top workers need to know:
How to access (safely) many different types of roofs, from flat to almost vertical pitches.
All the tips and tricks for safely using their ladders.
How to pick and set anchor points.
How to understand side loads to anchor points and avoid them.
How to set rope anchors.
How to work with a tight rope.
How to you protect yourself from falls over the rake edge.
How to use work-positioning systems.
How to self-rescue if necessary.
How to rescue a colleague.
How to Stop-the-Bleed, and basic first-aid.
How to recognize heat related illnesses and how to treat them.
Keep in mind, that just because you or your employees are in compliance with OSHA regulations, that does not necessarily mean that you are safe. For example, OSHA requires fall protection for working at heights over 6 feet, yet has no fall protection requirement for climbing up and down a 40 foot access ladder, and they seem to give you a free pass for roof inspections entirely, yet gravity still is diligently at work. They have regulations about the labels on ladders being in great condition (however many roofers cannot read English and in 30 years I've never seen a label written in Spanish). They have good regulations about the ladder extending 3 feet past the roof eve, yet nothing about tieing off the bottom of the ladder so it cannot slide out from beneath you.
Basically, we try to apply OSHA regulations as minimum standards of working safely. When we can improve a team member's safety by deviating from the normal standards (such as utilizing sternal fall arrest rings with a site-specific fall protection plan rather than dorsal fall arrest rings shown in the top photo) then we do so. The sternal fall arrest ring use is typical for tower climbers and rope access workers but is still unusual in the construction industry. If you are an employer, be sure to implement a Site Specific Safety Plan that explains why you are utilizing 1910.140(c)(22) and deviating from the standard 1926.501(b)(13) with your own policy, then stick to it.
If you are an employer, yes OSHA applies to you.
If you are an employee, yes OSHA applies to you via your employer. Unsafe actions, simply not wearing eye protection, or not using fall protection (even though it's a 4:12 pitch roof, may cost your employer $13,000 or much, much more. So, don't make problems for your boss unless you want to be unemployed.
Sole proprietor, probably not.
Small family business with only family members employed, perhaps not.
DIY'r/Homeowner, no.
OSHA officer off the clock at home, no.
Small LLC comprised of member-owners only, probably not.
Some realistic side notes:
Many roofing company employers that we've met send their employees to an OSHA 10 class, or OSHA 30 class. Generally, they do this in order to "check a box", hoping that this is treated as "training", hoping their employees learn what it takes to have safe working conditions, and hoping to avoid fines later during uncomfortable OSHA encounters. We believe it is absolutely critical to learn how to identify hazards, and the class can do some of that, but it will not teach the roofer or solar installer the most important things they need to know.
The roof top workers need to know:
How to access (safely) many different types of roofs, from flat to almost vertical pitches.
All the tips and tricks for safely using their ladders.
How to pick and set anchor points.
How to understand side loads to anchor points and avoid them.
How to set rope anchors.
How to work with a tight rope.
How to you protect yourself from falls over the rake edge.
How to use work-positioning systems.
How to self-rescue if necessary.
How to rescue a colleague.
How to Stop-the-Bleed, and basic first-aid.
How to recognize heat related illnesses and how to treat them.
Great training is critical for helping workers have safe working conditions. Explore the videos below or the Youtube link to our page in the Footer at the bottom of this page to improve your techniques or training. There's absolutely no logical reason roofing has to be hazardous. If you have questions, or would like more help, just ask. We are happy to help. Anchor in. Live long.
Our most popular video with over 185,000 views. This 10 minute video shows our complete approach to setting up fall protection before ever stepping off the ground.
The last person down still can easily have continuous fall protection. Why take an unnecessary risk at the end of any job? You've done the entire job perfectly, now it's time for the final descent and a grateful handshake from the client, not a trip to the emergency room or worse.
A 15 minute easy job and 30 minutes of safe access set up ... worth the time, every time ... especially if you want to remain agile and healthy for decades.
Good fall protection on rake edges sometimes requires a second rope.
Here we shown a complete (OSHA compliant) installation of our favorite temporary anchor, the V-1. We've tried everything available over the last 3 decades and are quite picky.
