Roof and Skylight Fall Protection Controls
Skylights are an excellent source of natural light that can create a happier and more productive work environment, along with energy savings benefits. However, skylights and skylight openings can present a significant fall hazard for workers on roofs conducting inspections, maintenance, repair, or involved in new construction.
Unfortunately, it is difficult to determine if skylights can withstand the forces of a fall. Unless you have skylights installed with integral fall protection screens, all skylights must be treated as a significant fall hazard. This article will address skylight protection methods/controls that are essential for reducing skylight fall risks, in the order from most to least effective. Keep in mind, while this article focuses on skylight fall protection, some form of fall protection must be provided for all workers on flat or sloped roofs, regardless of how far or close they are to a leading edge or opening.
OSHA’s Classification of Skylights
From an OSHA perspective, OSHA treats skylights as an open floor hole, and rightfully so. In industrial settings, OSHA 1910.28 (b)(3) states; “The employer must ensure each employee is protected from falling through any hole (including skylights) that is 4 feet or more above a lower level by one or more of the following: covers, guardrail systems, travel restraint systems, or personal fall arrest systems.”
Skylight Protection Methods/Controls
Building owners and subcontractors need to recognize and address the hazards of skylights. The first step is to conduct skylight risk assessments and focus on ways to protect every worker from falls – including employees and subcontractors. The next section will offer skylight protection controls to ensure the safety of workers on roofs.
Install skylights with integral glazing or screens that are rated for falls
The preferred method is to eliminate the hazard from the start. This would involve building owners, architects, and engineers working together and demanding that skylights rated for falls are installed during all new construction or renovation projects. For existing building owners, special consideration should be given toward budgetary planning to replace any skylights that are not fall rated. This control is essentially the most impactful and effective way to reduce hazards and injuries from skylights because of its ability to engineer out the hazard.
Install fall protection rated mesh domes/wire screens over skylights (secured to the curb)
Installing mesh domes/wire screens is an alternative control. Mesh domes/wire screens are available aftermarket products that can be purchased and are ready to be installed or might have to be fabricated by a firm that is qualified to do so and manufactured off stamped drawing. If you proceed with this method, ensure that the mesh domes are engineered to withstand the forces of a fall.
Install non-penetrating permanent approved guardrails around the entire skylight perimeter
Another option is to install non-penetrating permanent approved guardrails around the skylight perimeter. When guardrails are installed, it takes the human element of risk out of the equation for individuals working around skylights. Non-penetrating guardrails consist of a large base or weighted base that is capable of withstanding a force of 200 lbs., applied in any direction. Remember, the railing height must be 42 inches ± 3 inches with a midrail halfway between the toprail and roof surface.
If you decide to install guardrails imbedded into the deck, just remember that anytime you penetrate the roofing surface, you increase the risk of leaks!
Require workers on the roof to use a travel restraint system
A fall restraint system is generally preferred over a fall arrest system (addressed in the next section) when they are properly designed, installed, and used. This is a better option because it prevents the possibility of a fall occurring. A fall restraint system consists of the following features:
- A body belt, but there is no reason a full body harness cannot be used
- A rope or “tether” connected between the body belt or full body harness and the anchor point
- An anchor point capable of withstanding twice the anticipated forces applied from walking, leaning, or sliding
If you decide to implement a fall restraint system, it must be rigged to ensure that any 360-degree movement from the anchor point would avoid all skylights, roof openings, or leading edges. A fall restraint anchor could be the mobile type system pictured below, restraint installed anchors, or any other anchor on the roof such as lifting rings on air conditioning units that meet the minimum anticipated forces applied.
Require all workers on the roof to be wearing a personal fall arrest system
The personal fall arrest system is another approach to reducing skylight hazards through the use of personal fall arrest equipment. Below are the specifics of wearing a personal fall arrest system:
- A properly fitted harness
- Lanyard such as a static 6’ lanyard with shock absorber or a retractable lanyard in various sizes from 6’ to generally a 100’ maximum line payout
- Anchor point capable of withstanding 5000 lbs. of force
Anyone that wears, connects, or installs a personal fall arrest system must receive extensive fall protection training. Unlike fall rated skylights, aftermarket mesh domes, or permanent guardrails around skylights, a personnel fall arrest system has the potential for failure, such as an improperly worn harness, a lanyard that may not be properly connected, or an anchor point may not withstand 5000 lbs. of force applied.
In addition, an employee may simply forget to wear their personal fall arrest system while on the roof. This is the reason we recommend engineering out the hazard, with personal protective equipment as a last resort.
When using the personal fall arrest system, the employer is required to develop a fall protection plan anytime personal fall arrest is used. All workers suspended should be brought down or relived from the pressure of the harness within fifteen minutes of the fall to help eliminate the exposure from orthostatic intolerance, which can lead to death. The means of rescue could include on-site aerial work platforms, use of self-lowering retractable lifelines, or use of outside sources who can respond within that fifteen-minute timeframe.
To address the risk exposure presented from skylights, it’s up to the building owners, those renting or leasing a building, or contractors to assess all skylights and make sure one of the controls/methods listed above is implemented 24/7. For additional questions on skylight fall protection or the controls highlighted, reach out to Robert Tenhagen, senior risk manager at M3.