The Flat Roof Dilemma - When is Fall Protection Required with David Kozlowsky

According to BLS data, workplace fatalities from falls to a lower level were up from 615 on 2018 to 711 in 2019.  Fall hazard exposures exist in almost every industry and finding the right fall protection solution for you’ your situation is not always easy.  There are many factors that should go into choosing the best fall prevention method, especially when it comes to fall protection on roofs. On this episode of the MEMIC Safety Experts Podcast, I speak with David Kozlowsky, President and Owner of Safe Approach in Poland, Maine about fall protection requirements for roofs. Peter Koch: [00:00:04] Hello, listeners, and welcome to the MEMIC Safety Experts Podcast, I'm your host, Peter Koch. There are fall hazards in almost every industry or business, and personally, whether it's scaffolding, ladders, anchors, fall protection, arrest systems, rope access rescue or fall protection training and education, that all makes up a significant part of what I do with the businesses that I serve. And today we're going to talk about falls and specifically falls from a height and even more specifically, fall exposures while you're on a roof. So before we get into that recently, I got the chance to talk to one of my friends, who's another safety professional in a different area of the country. And we got to talking about fall protection and the excuses or reasons that workers and business owners have given us for why they don't or won't use fall protection on their job sites. So here are some of the ones that we've had in common, and I bet you you'll find some of [00:01:00] these are actually pretty familiar to you. If you're a safety professional and if you're a business owner, maybe you've used one of them yourself. I know before I got to be a safety professional, I've used a number of these to make an excuse of why I'm not or won't use fall protection. So the first one that came up, which was, I think, one of the more common ones, it's way too time consuming to set it all up. I can get the job done and half the time. If I can just get on the roof and do my roofing work, that's the first one, too time consuming. It gets in the way you talk to workers all the time that they're on the roof you have the rope gets in the way, the guardrails get in the way it just gets in the way. Another one is it makes me feel less safe. So the ropes are a tripping hazard. And honestly, I think maybe the pneumatic hoses are probably more of a tripping hazard than the lifelines, but it's all perception. So it makes me feel less safe. It limits what I can do. It's uncomfortable, and I totally get that. If you're in a harness all day long [00:02:00] on a roof, you've got enough discomfort up there from the environment and the pitch that you're on and everything else. So the harness can add a little discomfort to it. But again, it's an excuse, so it causes more of a hazard. Getting back to that makes me feel less safe. It doesn't add value to the job, so we quantify that one is it just costs too much. I can't bid successfully for a job against the guy down the road. He's not using fall protection. If I bid the job with fall protection, it's going to cost me way too much. I won't get the job. Another excuse that my friend and I have heard often is when I did buy it, my employees didn't use it, so I stopped buying it and asking them to use it. So they just kind of gave up instead of powering through and making it an initiative and part of the culture. But again, there's the excuse I'm only going to be up there for a minute. I can't tell you how many times I've heard that particular excuse, and more often I've [00:03:00] heard that excuse during an investigation or an analysis of why the fall occurred. So I'm going to a client and we're talking to them about why this person got significantly injured, falling off the roof, the ladder, the whatever it was. And the answer is, well, they were only going to be up there for a minute. I didn't think I needed to set up all of the fall protection. Another one, which is interesting because it's all about perception. Again, I've never used it before and I'm really comfortable working at height or being up on the roof. So my comfort level is driving the non need, I guess, for fall protection. Another interesting one is what we are using fall protection and I'm talking to the business owner and he's pointing up to the roof where his roofers are on roofing planks instead of actually a fall protection system. So that's not fall protection. We'll get into that as we talk through this in the podcast. And this last one probably was my most favorite. And it's more than just a statement. It's a couple [00:04:00] of statements. So bear with me here. So when I was asking this individual about fall protection on the job site, the answer was, Well, we have a safety monitor and that's all we need. Because for roofing, there is an accommodation there to use a safety monitor under very specific conditions. But his answer was we have a safety monitor. That's all we need. And he was saying this while he's pointing to one of the workers who was on the ground shoveling shingles from the ground of the dump trailer. But he was in an orange vest so that designated him as the safety monitor. But his buddies or the other workers were up actually stripping the roof on a 10 12 pitch. So the safety monitor was doing something else while the guys were up stripping the roof. And while I looked at him, the follow up to that was from the guy was, well, he's only there for a few minutes because he needs to stay ahead for the cleanup. And while the other guys are at the peak, he doesn't need to pay attention as much. He'll pay more attention when they get closer to [00:05:00] the edge. Like, OK, fine. Excellent. So all of those are different excuses, you'll hear them all over the place, but none of them really help you because there's a lot of stats out there that really drive the need for fall protection, and you can talk to anyone who has taken a fall off a roof or off a ladder, and I'll bet you that they wish that they had done something a little bit different, so they didn't have an event that changed their life. So if we look just at the stats, according to BLS data, fatal falls from roofs accounted for seven hundred and sixty two of the three thousand seven hundred and twenty two fatal falls between 2011 and two thousand sixteen. And that's just fatal falls. That's not all of the other types of fatal injuries that happened in the workplace. Those are just fatal falls back to 2016. And if we look specifically at roofing and some more current data in 2019 roofers accounted [00:06:00] for 111 of the five thousand three hundred thirty three fatal injuries. And that's just in one year, and it's up 15 percent from 2018. And the BLS data also shows that roofers have a fatal injury rate of fifty four fatal injuries per one hundred thousand workers. All right, so fifty four per one hundred thousand doesn't seem like a lot. Well, I guess to me as a safety consultant or just as a human, fifty four people dying on the job is a big number, regardless of how many workers you're comparing it to. But let's add some different perspective to that. So the average fatality rate across all industries, regardless of what the industries are, is three point five per one hundred thousand workers. So that makes the rate for roofing 15 times higher than the average. And it's only preceded by fishing, logging and pilots or flight engineers with a higher [00:07:00] fatality rate. And while those industries logging fishing in flight engineers have a myriad of different exposures that could cause fatalities and a significantly more limited set of choices for controlling the exposures, roofing fatalities come almost exclusively from falls and fall protection or prevention, or excuse me, roofing fatalities come almost exclusively from falls and then fall protection and prevention technology has really exploded over the last 10 or 15 years, and there's been a huge increase in what's available to the person working on a roof. So to help us explore fall protection and how it applies to roofing and tearing down some of those stats and maybe giving you some better ideas about what to do when you're on a roof, is David Kozlowski, president and owner of Safe Approach right here in Poland, Maine. So, led by David Safe Approach's team designs and builds fall protection equipment from harnesses, [00:08:00] anchors and lifelines to safety netting and custom fall protection worksite solutions. Over the years, they've developed some really creative fall prevention solutions for a variety of different industries. So David, you were on the podcast back in March of two thousand twenty one talking to us about the basics of fall protection. Welcome back today, and I'm glad to have you to talk about some more specifics. David Kozlowsky: [00:08:24] Peter, thanks. And thanks for having me back. It was a lot of fun last time and hopefully people got something out of it. And hopefully I can give you some good information that people can take back to their places of employment and help them implement safer work practices. Peter Koch: [00:08:43] Oh, I'm sure they will. There's a lot of great information on the other podcast. We talked about the hierarchy of controls and different types of fall protection and fall prevention that were out there and when to apply it. And I know we were talking before the podcast about how prevalent roofing [00:09:00] exposures or working on a roof. It doesn't have to be roof work, but working on a roof is. And just the other day I was driving down my road and two property owners were actually standing on the peak of the roof, installing a chimney lining. So there was not a stitch of fall protection. Well, let me tell you, the only fall protection was in my car driving past them. It wasn't anywhere on the roof, and you made the comment to me that you spend the majority well, quite a bit of your time having conversations with different clients about fall protection for roofs because it can get a little bit confusing, I guess. David Kozlowsky: [00:09:39] Well, all the reasons that you gave earlier are still very prevalent. I mean, I spend a lot of time in my truck driving around, and I can't tell you how many residential roofing projects that I drive by where I still see them not wearing fall protection. Even though the exemption was removed many years ago, [00:10:00] they still aren't wearing it or. I'll see them wearing their harnesses, but knowing what to look for, I can clearly see that they aren't connected to anything, so I think they often put them on. So at a quick glance, somebody driving by might think, Oh, there they are, they're wearing their fall protection, but it's not actually connected to anything. And I see it, you know, so often they still a lot of them, for all the reasons that you gave, are very resistant to it. And I don't think it's really going to change until we can help change the attitudes in the hearts and minds of the people that are actually there to be protected. If they don't want to protect themselves, it's really hard to overcome that mountain. Peter Koch: [00:10:42] Yeah, it really is. And if you've never fallen off a roof or had an injury like that, it can be difficult to understand why you need it. Because some of those some of the comments that were made to resist fall protection are the reasons [00:11:00] why I'm not using it are actually valid. I mean, they can be uncomfortable. They can, if you're used to not having vertical lifelines and something else on the roof and you're just used to having a naked roof that you're on maintaining or re-shingling or putting new roof material on it. It does get in the way. It's a change. It changes your workflow and work process. David Kozlowsky: [00:11:26] Well, all of those all of those excuses are basically variations of the one single most common excuse, which is not just used in roofing, I've seen it with confined space training with all kinds of other types of injuries that can happen not just fall protection. They're all variations of the same basic excuse, which is I've been doing this job for insert number here a number of years and I've never had a fall, so [00:12:00] I don't feel that I need it. And I've heard that excuse in rooftop safety and confined space safety and all kinds of industrial safety applications where people just don't think they need it. I've been doing this job for 30 years and I've never even had a close call. Why do I need to do this different thing now to protect myself? And it all goes back to what you just said. If you've never fallen off a roof or if you've never got your hand caught in the machine or, you know, you've never tripped and fell into a hole or never been run over by a truck. You don't think that you need those protections. I mean, again, it's the attitude of the user is trying to overcome the attitude that you don't need it. And once you overcome that mountain, I think people will get a lot more receptive to it. Peter Koch: [00:12:51] Yeah, I'll relate a quick story. I have a good friend of mine that I worked with in a previous industry, and he and [00:13:00] I share a love of climbing. So he's got a great climbing background. And after we had a downsize at the company that I was working at, he actually went to go work for a local roofing contractor, and he actually brought that skill sets and understanding of not just fall prevention and fall protection, but actually if he's going to be setting up aide climbing or setting up protection on a rock face someplace. He wants to be able to work with both of his hands. So he sets up positioning. And so he brought a lot of that information to the company. And interestingly enough, when I got to work for MEMIC, he was one of or at that company was one of the first companies that I was assigned to from a construction standpoint, and I met him again on the job and I was looking at what he was doing and he had taken a lot of that thought process of, look, I get it. You know, from a fall standpoint, this is really not a whole lot different than if I'm climbing [00:14:00] somewhere in the wilderness. I can use that same technology to make my job actually a little bit easier to be able to feel comfortable. I mean, if you're installing metal roofing panels someplace, it's hot, it's reflective, it's slippery. Why can't you set up a system that will allow you to actually work more effectively right in there so it can be done? It totally can be done, David Kozlowsky: [00:14:24] And you just hit the nail right on the head. Most of the reasons why people don't want to use it is effectiveness of the fall protection. It's, you know, it doesn't. It doesn't do any good to set up a system that's technically quote unquote compliant that it doesn't work well. And I literally just this week went to look at a client who was looking to. They just had 11 ladder climb systems installed on some silos. So they had silos with these ladders and somebody [00:15:00] came in and said, you. Need to put climb systems on these, they installed it and the employees were complaining, so when I got there, the argument was is these aren't compliant? Well, I went and looked at them and they were. Everything was as it should be. But the ladders were too narrow and they had installed them, you know, in the center of the climb. And there was it was when I climbed the ladder, I found that it was extremely difficult to get between the ladder climb system and to step through and get on to the top of the tank. Very difficult. And when I came down, I said, I have to agree with the employees. This system is compliant. But it really isn't set up to be very effective. And so they were hoping that I could come in and figure out a way to modify and change or provide something new that would be a little bit more seamlessly integrated [00:16:00] into what they had and make it not just compliant but actually usable so that the workers felt safe and felt better using it. And you know, that's one of the other big things, especially with roofing is you were talking about in the beginning is not just the culture or the attitude, but you know, there is a certain amount of it that is cumbersome. It does get in the way, it's not easy and we haven't invented the perfect integrated seamless system yet. So, you know, we kind of have to work around that a little bit, but you can try to do things to make it as effective as you can and as seamless as you can with what's available out there. Peter Koch: [00:16:41] Cool. So we'll definitely get into that because I think that's a great discussion about what would be effective. And it's going to depend on the environment, the work that you're doing, the skill set of the people that you're going to have always it's going to have some price component to it. So because you know, you can always you can look to get the Cadillac or [00:17:00] you can look to get the jalopy one of the two regardless of what you have. If it is compliant, it definitely needs to fit within the work that you're doing to keep it effective because there's always that balance. We talked about this last time between safety, productivity and the quality of the work that you're doing. And if those aren't in balance, then something's not going to work well. And I think in the case of the silos, right, they focused on the safety component, but they missed the productivity and the quality component like you can't, David Kozlowsky: [00:17:31] Right? Peter Koch: [00:17:32] It wasn't functional for the work that they were doing. David Kozlowsky: [00:17:36] Right. And that becomes that's going to become plainly evident when we start talking about low slope roofs, because that's one area where there really is a vast difference between, you know, effectiveness and costs in some cases and the seamless integration on the on the flat roofs. Peter Koch: [00:17:53] Yeah, very true. All right. Awesome. So let's jump in and talk a little bit about the requirement so that OSHA has a duty [00:18:00] for fall protection and it's both it's a little different in construction and general industry. So could you talk a little bit about what OSHA requires for fall protection in the construction industry and in general industry? David Kozlowsky: [00:18:15] Sure. Well, there's obviously a million different areas we could touch on, but sitting in fall protection and kind of talking about roofs and kind of narrowing it down a little bit. You know, the major differences are construction. The construction standard has a different kind of set of rules for construction operations or the act of roofing, whereas the general industry standard does not, the general industry standard has a set of rules that apply to all. I get this question a lot. If you know John Smith works for XYZ Company and he's up there patching a roof, isn't he in, you know, roofing operations? So his standards [00:19:00] are different, and that is not true because he's not a roofer in the act of roofing. He's still under general industry. I get that question a lot. So the biggest difference is that in for most of your clients that are not construction related clients, they should be following 19 ten and not nineteen twenty six. They should be following the general industry standard. There's a slight difference in the height standard general industry as a four foot rule, construction has a six foot rule for most applications and some slightly different ones for connecting steel and some other things. But across the board, mostly it's roughly six feet. So those are the main differences. And then other than that, they both point towards the same standards. If you look at the requirements for safety nets or guardrails or personal fall arrest systems and the loading requirements and all of that, they all point to basically the [00:20:00] same thing. So the quality. Of product that you can use to solve either one is the same, so there's no difference there. And so I think what we're going to do is probably focus maybe a little bit more on the general industry. I guess today it's kind of confusing, but 1910.28 has a lot of information in it. And the construction standard, other than removing the exemption for residential roofers, hasn't that portion subpart M hasn't really changed significantly in the last number of years, so I feel like the listeners are probably pretty well up to speed on that. So maybe we'll focus a little bit more on the general industry. Peter Koch: [00:20:48] Yeah, I think I think we will. There's a that's a big topic, but before we delve into that, I think it is important to restate that it's been a number of years already since the [00:21:00] fall protection exemption for residential roofing has gone by the wayside. So that is no longer. If you are doing residential roofing, you are required to have fall protection when you are six feet above the ground or a surface above the surface that you're working on. David Kozlowsky: [00:21:18] Correct. Peter Koch: [00:21:19] So you got to have it. And there's multiple different ways to do that. And there's some different requirements if you're on a low pitched roof versus a steep pitched roof. And maybe we can spend a moment defining those two things because it gives a different threshold for the level of protection that's necessary. David Kozlowsky: [00:21:37] I was going to say most of your residential roofing would fall under a steep pitched roof. I know there are some houses built with a low, low, low slope, but most of them would fall under the steep. But OSHA defines the line of demarcation at four 12, four over 12, so four inches of rise and 12 inches of run. If [00:22:00] the roof is four 12 or less, then that's considered a low slope roof. It's walkable, and so the standards and rules are a little bit different. Once you get above four 12, that's a steep slope roof. A lot of the options for steep slope roof go away. A lot of options that you have for low slope go away, it becomes very limited. So on a steep pitched roof, you have basically, for practical reasons, pretty much personal fall arrest systems. You do still have guardrails which are extremely difficult to set up, especially on a residential roof. I've never seen anybody really do it effectively. Safety netting is still an option, but it's not really practical. So for a steep pitched roof, you're mostly limited to a personal fall arrest system, which would include some type of anchor, a connecting device that includes some sort of energy absorbing device [00:23:00] in it. And then your harness the big three. Peter Koch: [00:23:03] Yeah. And I think for those specifically for like the difference between your guardrail system, which is what you'd normally want to see from an engineering control standpoint for fall protection, you can set up on a steep pitched roof a good system that will prevent you from getting off the roof in the first place or falling off the roof in the first place. So if you slip and fall on the roof and you don't fall off the roof, you're eliminating the need for rescue. You have probably much less significant injuries that will occur if you're on a steep pitched roof, and all you ever do is put guardrails on the bottom and someone takes the big whipper from the peak of the roof. You're probably going through the guardrail because the requirements for guardrails are like we talked about the last time 200 pounds in any direction. If you're a 200 pound guy and you're sliding down the roof, you're hitting that guardrail with a lot more than 200 pounds of force. So you're going to the ground. David Kozlowsky: [00:23:58] Yeah, so the [00:24:00] options are a little bit more limited as far as tying off on a steep pitched roof. There really is very little reason or excuse in today's day and age why you can't other than making excuses about it being too hard or too difficult or too cumbersome. Other than that, there's plenty of product available. I don't care what kind of roof that you're working on. There's probably something out there that's compatible may require a little extra effort or work, but it's definitely there's definitely plenty of product out there that's available for that. Peter Koch: [00:24:37] Sure. And I think what you're talking about is really the anchorage, right? So that's the bigger challenge for most folks of where and how and what do I use to set up my anchor to connect my lifeline into or my lanyard into? And that becomes somewhat of a challenge. But like you said, there is a myriad of different types [00:25:00] of anchors that can be used. Out there, some which will penetrate the roof and some will not penetrate the roof, even there's plenty of different options out there for you. David Kozlowsky: [00:25:10] People just need to research what's available for options for residential roofing. There are different ways to set up a system which can make it easier and simpler. One of the biggest problems is rope management. So when you talked about setting up a system so that someone wouldn't fall off the roof, that requires good rope management. And so ninety nine percent of the complaints that you listed for a residential roofers basically center around the rope management so you have your ropes and your grab and you're constantly if you're doing it properly, your rope is almost always in one hand, and whatever you're doing is always in the other because you're always adjusting, especially if you're nailing shingles. Those guys are going back and forth on the roof so much it's almost [00:26:00] impossible to employ effective rope management. If you're not switching Anchorage points or if you don't have different people working in different sections of the roof because rope management can become, you know, dangerous if you're not paying attention to it. So in an effort to have freedom of movement and not get held up, most of these guys will just pay themselves out a bunch of slack behind the rope, grab and the anchor. And so what could potentially happen if someone fell off the roof as you could hit the ground before the rope gets taut, depending on how high the roof is and how much rope you have paid out so you can move around, it's basically you're putting it on for looks, but it has actually no functional value whatsoever. And so to manage that, it is a little bit more difficult a retractable [00:27:00] is a better solution. But there's a lot of people that would disagree with me on that. There's been many case studies done about retractables on pitched roofs and how quickly they lock up and the potential for someone to slide off the roof and actually not engage the retractable because they're not moving fast enough. So it doesn't think they're falling. So that would be ineffective in preventing them from necessarily falling off the side. But it would turn into, you know, a free fall once you went off the side. So there's many different people that have many different arguments on that, and I don't know that there's really necessarily a right answer other than the manufacturer. So you should always go back to the manufacturer if the manufacturer allows the retractable on a pitched roof, you can use it. If the manufacturer says no, then you, then you definitely shouldn't. But rope management is definitely the biggest complaint and the biggest area I see [00:28:00] with problems with roofing. So if we could find a way to make that easier or find ways for companies to plan the jobs to make it a little bit easier for the workers, then that would remove quite a few objections. Peter Koch: [00:28:16] Yeah, I'm sure that's a big objection that you have and you have a large roof where you have multiple people up there, even if it's just a couple of guys up there and they're crossing paths. It can be challenging just managing your own rope. And then, like you said, making sure that I don't have slack, that my rope grab is always at my anchor or higher. That provides the greatest level of protection for me because as you said, if I pay out enough slack to be able to move anywhere on the rope or anywhere on the roof that I need to without having to manage my rope grab. And I do take a fall. You may hit the ground or if it's high enough, you may not hit the ground, but you pull your anchor out because it's not [00:29:00] designed for the forces that the extended freefall will cause. David Kozlowsky: [00:29:06] And that's the biggest fear to me and to probably a lot of other people, too, is because, you know, if the product is not being used properly in a lot of cases doesn't really matter. Once the lawsuits start flying around, it very much becomes more about percentages and bean counting and how who, which companies we can get to pay out, how much money, rather than whether or not the person was actually at fault or not. And so that's a big fear to me and to a lot of other people with the roof anchors is, you know, they're only designed to hold a certain amount of load and used properly. They are fine. But as you said, if you're if you don't have or if you have too much rope paid out and you overload the anchor, I mean, it could, you know, it could come off the roof and then we're stuck proving [00:30:00] that. Wasn't the anchor that failed, that it was the usage and that can be that can be difficult sometimes. Peter Koch: [00:30:06] Very difficult, very, very, very difficult. David Kozlowsky: [00:30:09] And it behooves employers to pay attention to that too, because, you know, most of these contractors, you know, they leave it up to the employees to, you know, use the fall protection and they don't really pay attention. But I have news for all of them. They're going to get drug into it just as much as anybody else. If an employee falls off a roof and gets injured severely, even to the point of maybe disabled or worse, everybody's getting sued, including them, and they're going to start looking at their safety policies. They're going to start looking at their safety plan. If they have anything written up, they're going to look at the job. Was anybody paying attention to what they were doing and out of sight? Out of mind is not a not a good thing. Peter Koch: [00:30:56] No, not a good thing at all. And those are some basic requirements that OSHA has [00:31:00] from a compliance standpoint. They require training. They require you to have a plan before you go up on the roof. You're required to have the appropriate equipment for the hazards and exposures that your people have and that they're not exposed before they have training and access to the proper equipment. So those are all parts of the general fall protection requirements that OSHA has, whether it's construction or general industry. I wanted to back up just a second and ask you a question, and this is kind of in setup for a steep pitched roof. And these are this is not going to be a hard and fast piece. But in your experience, as you are looking at a roof or talking to an employee or an employer about setup, how do you assess a steep pitched roof as to where might be the best places to put your anchorages? Are there any recommendations that you would feel comfortable talking about? David Kozlowsky: [00:31:59] Yeah, so [00:32:00] a lot of it centers around the conditions of the job. So you're going to want to look at the size of the roof and you're going to want to look at, even more importantly, the fall clearance distance between the roof and the ground. There is a lot of fall protection out there that were you to be working and actually fall off the edge, may or may not arrest a fall, especially in residential. I mean, if you're looking at a, let's say, a six 12 pitch on a ranch, you know, a low built ranch on the eve of the roof may only be, you know, 10 feet or even less from grade. And so, you know, if somebody's standing near the leading edge and falls off, I mean, it becomes highly critical that the system was set up and is being used specifically if you even have any hope of arresting that fall before someone falls off. So [00:33:00] a rule of thumb that I try to go by is 15 degrees off perpendicular. So you want to look at your roof and you want to take a measurement on the length of it, and then you want to draw up a perpendicular line from the peak down to the to the eave. And then you want to draw two more lines in a V-shape from the peak at 15 degrees on either side. So you're drawing like a 30 degree window. And so what you want to do is you want to set up enough. If you're going to use a peak anchor and not a line of some sort, you want to set up enough peak anchors so you have the entire edge or eve of the roof covered in those 15 degree windows off perpendicular. That's a good rule of thumb. Number one So it's not really easy to say put one every so many feet or this or that, because depending on the length of the run and the length of the ridge, I mean, those can [00:34:00] all affect, you know, how often you may put one every 12 feet or 10 feet or even six, depending on what's going on. So to say X number of feet doesn't work. The 30 degree window is a much more effective system. And so what that does is that sets up enough anchors so that you can work an area. Your line will not be too far off center, so it gives you a good working area. It helps limit and prevent pendulum falls, so it prevents you from being tied off too far away from the anchor so that if you fall, you don't swing towards perpendicular because that's what's going to happen and then risk impacting something below you or even the ground. And it gives you enough points to have multiple workers up there so that each, you know, we recommend each one takes a zone. I know a lot of these guys like to lay shingles and literally run back and forth the entire length of the roof with the nail gun. [00:35:00] But. With this kind of thing that's really just not that practical. You're going to tangle up your ropes, tangle up your air hoses and tangle up everything, so you have enough anchors that there can be enough guys working their own zones to get that accomplished. So that's kind of a rule of thumb that we use that really helps setting up and then again, management paying attention to the amount of rope between you and the anchorage point. Peter Koch: [00:35:27] That's great. That's really good advice that 15 degrees off and then have overlapping zones so that you cover the entire roof edge. Good. I think that helps. So let's move from our steep pitch roofs because we'll have another we'll focus on that. Maybe another podcast. But what we really wanted to talk more about is that low pitch, that low sloped roof or a flat roof. And granted, there's a lot of roofs out there, not so much in the new England area from a [00:36:00] residential standpoint, but certainly commercially. There's a ton of flat roofs out there and there are some rules around building or constructing a flat roof that would be covered under the construction standard and some different operations. But once that's done, once it's built, the majority of the time, you're going to have employees or contractors up maintaining either the roof or the HVAC units or the skylights or something else that's up there. So let's talk some more about the low slope or a flat roof and how or what are the what are the standards and how does fall protection enter into managing the exposures around a low pitched roof in general industry? David Kozlowsky: [00:36:48] Sure. So the first thing is people need the first thing just by way of introduction is that people need to start thinking about their roof as another floor of their building really [00:37:00]. Most people don't. They think about the roof as being out of sight, out of mind. But OSHA considers it another floor of your building. If employees are going up there and doing work, which means all of the same standards that apply to general industry for work inside also apply on the roof. The four foot rule, the unprotected leading edge open floor openings, which would be skylights or roof hatches. I mean, all of those things, it's a walking working surface. And so kind of what they did with 1910.28 I felt like was they included low sloped roof into the walking working surface, integrated much, much more deeply to hopefully help people understand that, you know, unguarded floor openings and edges and whatnot on a roof are the same standard as they are inside your building. So what they did was [00:38:00] they took some of the construction standard and applied it. But then they included a lot of things that are not included in the construction standard. So what I can do if you want is just do a brief overview of what the what the standard basically says. So for low slope roof, for activities on the roof, even if you're patching a roof because you're not actually a roofer in the act of roofing or construction, you're just making a repair, which is maintenance. So even if you're repairing a roof or patching a hole or working on HVAC equipment, that's all wrapped into maintenance of the roof. So OSHA set up three zones now. So the old interpretations of there's no safe distance from the edge and all those vague things are pretty much gone away. They still don't feel there's any safe distance from the edge. However, they have at least now [00:39:00] set up some lines of demarcation and some options from what for what you may or may not do within those areas. So the two lines are six feet and 15 feet is the two distances that you need to remember. So your whole roof area should be protected, and the most dangerous area is area within six feet of the edge. They've highlighted that is obviously the most dangerous. You're the closest to the edge, a trip or a slip, you know, could easily lead to going over the edge. So any work or any activity at all, even if it's just walking and not working any activity at all within six feet of the edge of the roof must have a guardrail, fall arrest, fall restraint, personal fall arrest, a safety net, something. There's a list of things that they put in that you're allowed to do. They mostly center around guardrails, personal fall arrest and safety nets, and then fall restraint also kind of gets lumped into personal [00:40:00] fall arrest. So, but if you're within six feet of the edge, you either need to be tied off one hundred percent of the time to a horizontal lifeline or roof anchors or something, or have a guardrail or a safety net if you're within six feet of the edge. So the next area is what if I'm not quite six feet from the edge, what if I'm just a little bit more than six feet? What do I have to do? So the next line of demarcation is 15 feet. So if you're in a in a zone on the roof, that's between six feet and 15 feet, you have the same options that you had before. You can put a guardrail or you can have a horizontal lifeline or roof anchors or safety netting or some other form of fall protection, but they've also opened up an area of a designated area. So from six feet to 15 feet, if you are up there temporarily and [00:41:00] infrequently, they will allow a designated area. So what is temporary and infrequent? Well, they define it in the preamble. They don't really say it in the standard, but in the 500 page preamble to the standard that they came out with, they kind of they kind of defined temporary as two hours and they define infrequent as monthly. So if you're performing monthly maintenance, you are not up there infrequently. And if you're up there for more than two hours, you're not up there temporarily. So if you have an HVAC unit up there and you only go up twice a year to replace a filter, but it takes you more than two hours to replace the filter. That's not temporary and infrequent because it doesn't meet both standards, and it's important to remember that your roof area is considered one area, not just spot that you're working on. So this is the thing that I deal with all the [00:42:00] time. It's like, Oh, well, I'll just put a guardrail right here where this unit is, and I'll cover the standard. Meanwhile, there's 14 units on the roof, and they might only spend 30 minutes at each unit, but they're up on their roof for an entire day, working, replacing all these filters. So your whole roof area becomes the standard that you need to meet, and there's a few different ways we can. We can approach that. But just by way of general knowledge, if you're up there temporarily and infrequently, which means you're less than once a month and you spend less than two hours, both of those are met, then you can do what's called a designated area, which means you can set up a warning line system as long as you stay behind it. And it's very important to note that a designated area is very specific. It is a physical barrier between you and the edge of the roof. It is not a line painted on the [00:43:00] roof. It's not a sign posted on the thing saying don't go past this line. It is a physical barrier with actual standards. A warning line should be between thirty nine and forty five inches tall and must have a two hundred pound brake strength minimum and has to be visible from 25 feet away, and the posts need to withstand 16 pounds of force at the top. So all of those standards point to no, you cannot paint a line on the roof and call that your warning line. It's a physical barrier, and there's a bunch of reasons in the preamble they give why a warning line's a physical barrier, but you can do that around areas if it's temporary and infrequent. So then we've established now, OK, let's say the roof hatch comes up in the middle of the roof and all of my equipment is centered towards the center of the roof. Do I really need to do anything now because I'm more than 15 feet from the edge?  [00:44:00]So at 15 feet, if all of your equipment is set up more than 15 feet and you're up there regularly, you know, like I said, monthly maintenance or weekly maintenance if you're up there regularly. Yes, you are still required to have something. You must still have a designated area to corral people into where they're going to be working. So we erect a lot of warning line at 15 feet back from the edge, where rooftops don't have units that are closer than 15 feet and they're much further towards the center. So we set up a designated area at the center of the roof, 15 feet back. We put the warning lines. You can go up there as much as you want and do as much as you want for as long as you want, if you have that designated area. If you're a small company and it's more than 15 feet from the edge, you have one unit [00:45:00] on the roof, you go up there once a year and you change a belt in the filter and it takes you a half an hour to do that. That is definitely considered temporary and infrequent. OSHA does allow you to not do anything under that rare situation. It's temporary and infrequent. You do not need to install any type of designated area or fall protection. However, controls would definitely need to be in place. So just because someone tells you, no you don't need to install any fall protection doesn't get you off the hook. And I've done quite a few things on this telling people, you know, they say, What do I need to do? And each situation is different. But at a minimum, if you have a roof that's temporary and infrequent and you're allowing employees to go up there without fall protection, we would recommend that minimum a roof sign off sheet for people that go up there to sign off, that they've had rooftop training. [00:46:00] We recommend that you have a map of the roof with a walk path delineated. And during the training, you tell employees this is where you may and may not go and this is where you stay and have them sign off on that. The roof itself should have a delineated walk path. There should be pavers or the glued down path or something. There should definitely be a delineated walk path from the entry point to the thing, and the sign off sheet should make sure people commit to staying on the walk path and not deviating from it. So those are at a minimum, a few things that people should do to cover themselves, because one of the big reasons why OSHA said there's no safe distance from the edge is because employees wander. They do it all the time. I've done it and he's sitting on a roof and you're walking around and you get bored or whatever. So you, you know, you walk [00:47:00] over to the edge and you look down to the parking lot, you see what's going on, and lots of people do that. They wander. So you want to make people sign off saying that they're not, you know, they're not going to deviate from that walk path. So that's at a minimum. Those are the kind of things you should do. So yes, there is a rare instance where you don't need to have fall protection at more than 15 feet from the edge, but it has to be temporary and infrequent. So those are the those are the three zones, the two lines of demarcation, six feet and 15 feet. And when you can and can't use a designated area or a physical, you know, fall protection or prevention system, and that's all in 1910.28, I think it's B 13 because the paragraph and it's all in there and you can review that. But those are those are basically the zones now. Peter Koch: [00:47:58] Let's take a quick break at MEMIC, [00:48:00] while we strive to help our policyholders prevent workplace injuries, we also understand that they do happen. No workplace is immune. And when they do happen, a solid injury management plan must be in place, including reporting and a return to work program. Statistics show that returning an injured worker to work in a temporary modified duty capacity instead of keeping them out of work until one hundred percent, will reduce both the length and cost of the claim, as well as increased the likelihood of a positive outcome for the worker and the employer. Did you know that MEMIC has created a seven step process for developing a return to work plan, as well as a matrix to rate your current plan against what our team has found to be the gold standard in return to work programs? Check out our claim, reporting and return to work resources at MEMIC.com/employers. Now let's get back to today's episode. Peter Koch: [00:49:03] That [00:49:00] makes sense, and I think there's a lot of information there. But it does make it a little more clear, so temporary and infrequent, you know, it is kind of unfortunate that they buried that in the preamble with those definitions are because I know that that information is or that question has come up quite often. What does that mean? But that was a great answer. So, you know, less than less than a month in less than two hours. And then the other point you made it shouldn't be lost on our listeners is that the roof is an, take the roof as an entirety. You could have one unit or you can have 50 units up there. And again, it doesn't matter if you're going to spend 30 minutes at one unit or 30 minutes on the roof, right? If you're going to spend 30 minutes at each of the 50, it's still going to be beyond that temporary requirement. So then you're moved into. I need to do something. I need to do something different. I can't. David Kozlowsky: [00:49:58] We've done a couple of roofs [00:50:00] where people have that situation where they have like I can think of one roof in particular that had a half a dozen units on the roof and they were all within 15 feet, not quite to the six feet mark, but within 15 feet. And so at each one, individually, they could maybe make an argument that it was temporary and infrequent. But the roof area itself, when they're up there, they're walking around and they're going from unit to unit and they're not paying attention to where they are. And so what we were able to do is we went up and we kind of corralled each unit with a guardrail and then we just set warning lines back 15 feet from the edge and then just had little pathways connecting the central part of the building to each one. So the employees were corralled within an area that was designated that you don't go out of this area. And then as they approached closer to the edge where they had the actual unit, there was a physical hard guardrail to meet to [00:51:00] meet the standard so you can do hybrid type systems. We do hybrids all the time that are combination of physical guardrail barrier and then designated area to keep people corralled and within the area that you want them to be. Peter Koch: [00:51:17] Yeah, great idea hadn't even really thought about it that way. I tend to be more black and white when it comes to some of those solutions, and that hybrid solution might be very effective. If you've got, well, if you don't have the ability to put guardrails up on the entire perimeter of the roof, which would be the most simplistic solution. But there is a lot of equipment to make that happen. David Kozlowsky: [00:51:40] This goes back to what you were saying when you just said that this goes back to kind of our discussion back at the beginning about, you know, seamlessly integrating and the cost. So the most effective solution, the simplest and most effective and best solution is for, you know, if you're up on the roof, you just put a guardrail around the perimeter [00:52:00] of the roof. Problem solved. You can have as many people as you want up there wherever they want. No limit. You can do whatever you want. You can shovel the roof, you know as much as you want and you're completely within the standard. But it's also really expensive. I mean, a lot of guardrail. Sometimes the weight is an issue. If we can't do penetrations, they want to do counter weighted guardrail. You know, with all the weight up there, sometimes that's an issue in the cost. So you know, there's definitely there's definitely the simplest and easiest solution isn't always the most cost effective. Peter Koch: [00:52:33] Yeah. So that's a great point. And it gets to the fact that you, you know, as a business owner or building owner, if you have a flat roof that you, you have to have people on, it may be worth your while to jump out there and contract with someone to do an assessment to figure out what are your options because you might want to say, Yeah, I can do that, we can put up guardrails all the way around the roof. [00:53:00] I hadn't even really thought about the if I can't penetrate the roof, from my stanchion, for my guardrail now, I have to have a weight that's going to allow for that 200 pounds of outward and downward force. And that's pretty substantial when you start thinking about how many stanchions you need on some of these large commercial roofs. So yeah, it's a really good point. Reach out get some help. David Kozlowsky: [00:53:21] Yeah, get some help. And each in each situation, you know, is unique. A lot of them are unique. So we have the ability to have a combination, like I said of guardrails and maybe warning lines or other solutions that might help somebody accomplish what they are trying to do without breaking the bank, so to speak. Peter Koch: [00:53:46] Yeah, great. Hey, so I've got a question for you and it's around access. So I got I don't have internal access to my roof. I have to have external access to my roof for whatever reason, right? Didn't get didn't get [00:54:00] planned correctly. Didn't wasn't in the budget to put internal access in, so I'm climbing up on a fixed ladder or maybe even a portable ladder. And how do I manage that type of thing within flat roofs? So what is what are the requirements around access zones? David Kozlowsky: [00:54:16] So what we usually do with a fixed ladder, first thing to do is look at the look at the height of the ladder. So if it's under twenty four feet, you don't need to do anything specifically with the ladder itself. But if it's over twenty four feet, then the ladder itself needs to have fall protection as of November of twenty eighteen. The standard for ladders was changed to basically say anything produced after that state after that date should not have a ladder well or cage on it and should have active fall protection. And then basically it was left that after November of twenty [00:55:00] thirty six, that I think the original standards said that all ladders had to have the cages removed. But I think they changed that to say that they only had to be removed if they interfered with the function of the fall arrest system. So if it's over twenty four feet and you have a cage, if it was built before twenty eighteen, you're currently OK. You have until twenty thirty six to upgrade that in retrofit it. But if it was built after that date, it should not have a cage on it and it should have an active fall protection system. So what we do, what we try to do with the ladders is once you once you've established that the ladder itself is safe and it meets the standards and it has fall arrest if it needs. Usually what we do is depending on again, the layout of the roof. If it's a small roof and there's it's densely compacted and there's a bunch of things up there. Normally what we just do is try to ring the roof in guardrail, [00:56:00] tie the guardrail into the ladder and put a swing gate at the top of the ladder. So you always want to have that swing gate just because that that becomes an entry point or an unguarded opening at the side. So if it's a larger roof and there's not a lot of stuff right in the area. What we usually try to do is we try to put like a little corral or a little runway. So we try to get back 15 feet from the edge of the roof, or sometimes 10 feet, depending again, on the usage and how often you're up there. But we try to get back at least 10 or 15 feet with a hard guardrail, little runway or corral with a swing gate at the end of it. And then we tie that into either additional guard rail or a warning line, a designated area from there. So we try to corral people to approach the ladder down a guardrail area. So as they approach through six feet from the edge, they're protected in between the guardrails [00:57:00] with a swing gate at the end, and then they can open the gate and get onto the ladder from there. Peter Koch: [00:57:06] Yeah, so full protection all the way through from the time you step into that six foot danger zone until you either get back onto the ladder to climb down or you get into the area that's beyond 15 feet or the workspace that you're within that warning line area. David Kozlowsky: [00:57:24] Yes. Yeah. So we usually tie hard guardrails back from some thing, either warning line or guardrail, or sometimes there is nothing. What we've done and we've done it a few places is we'll put a kind of the runway to the ladder with a gate and then at the end of the runway is either an anchor point or access to the horizontal lifeline system. So when they come out, they go on before they exit the kind of corralled area they hook on to the fall protection and then they go on the roof from there. That's most common on [00:58:00] roofs that have a little bit of a slope to them. I could think of one client that has it's a pretty low slope. It's definitely under four 12, but it's a white TPO roof. So when it's wet or if it's even snowed at all, it is absolutely treacherous. And so we definitely wanted 100 percent tie off up there. They didn't want to try to ring the guardrails all around. I'm not sure that it would have worked anyway unless they were permanently mounted because of the slipperiness of the roof and the counterweight and the fact that it was sloped. So it probably would have had to have it permanently penetrating. So we made sure that there was a swing gate at the ladder, that it was tied into the ladder, that it was highly secure all the way back to the point where they tie off onto the fall protection. So that's another option as well. You can always tie that runway back [00:59:00] into an anchor point. Peter Koch: [00:59:03] Yeah, that makes sense, and I haven't seen it employed, but I can see where that could be employed well, especially from a snow removal standpoint as we think about the New England area and you might have a multi-tiered roof where you might have a steep pitch above, but you've got an overhang that is within that four 12. And just to be safe on that, as you come up to stand on that, it's going to be less than six feet sometimes and having that horizontal lifeline running behind you that I can tie into and then shoveled down to the leading edge of that roof and then come back to shovel against the end. David Kozlowsky: [00:59:41] So, that goes beyond. So that goes beyond a kind of a controlled access zone into what we call a designated area. Peter Koch: [00:59:50] Ok. David Kozlowsky: [00:59:51] So we've done that quite a few times on roofs. So especially for shoveling operations on large roofs. One of the complaints is, well, I you [01:00:00] know, first of all, this snow up there, I can't tie off to, you know, roof anchors because they're buried in snow. The cables are buried or I need 10 guys up there shoveling and your cables only rated for two. I can't have five cable systems running around the whole roof. I mean, it's just not going to work. So what we do is a designated area. We take a section, we take the warning line and ring the roof with morning lines. So you can have basically as many people as you want back from the edge shoveling snow to one or more designated areas, which are areas closer than 15 feet where employees will stay permanently as movers to get the snow from the roof off the roof. So in those areas, what we do is we warning line it or guardrail it off and then install a couple of anchors so that when they go beyond the warning line and remove the warning line, they go into an area that has [01:01:00] anchors for fall protection. Those employees stay in that area tied off and move the snow off the roof and have everybody else kind of feeding snow towards them for shoveling. So again, another hybrid solution that's not uniform throughout the roof, picking pieces that work the best for each area. Peter Koch: [01:01:20] Now that makes, it makes sense. And I'm thinking it from thinking about it, from a business owner or a building owner standpoint. You might not actually have your guys removing the snow, but if you're installing a system like this, you're going to need to do a little bit of training about how this particular system works with your subcontractors so that they can take advantage of the safety or the protection pieces that you have, regardless of compliance, because again, go back to a comment that you made before. If one of your subcontractors falls off the roof at some point in time, you're going to get hauled into that lawsuit, or you're going to get hauled into the worker's comp claim as well. So regardless of how it works, you're going to get [01:02:00] tied back to it. David Kozlowsky: [01:02:01] From that, you're much more versed in that area than I am. So you would have more information about that other than I do know there is a bit of gray area in this particular type of applications to fire is who's actually responsible for the fall protection. The way it's mostly been handled is the building owner provides it because usually what happens is they'll say, OK, you can't do this unless you have fall protection, and then they'll either put it back on the contractor to bring all of their own fall protection, which becomes difficult when the roof is covered in snow. So the contractor kicks it back to the building owner and says, Well, OK, that's all fine and good, but what do you expect me to put up there when it's already covered in snow? So there's a little bit of gray area there. I know for building maintenance, especially façade maintenance, which is a different set of standards. We won't go into that today. But if façade maintenance, if you're over the side of the roof suspending doing [01:03:00] anything that does fall back on the building owner exclusively. So that's definitely there's no gray area there. But for this, I'm not really sure. Maybe, you'd have some insight into, you know, who is actually ultimately responsible for this or is it basically what I've been saying? It's basically an agreement between the building owner and the contractor as to who's going to supply it. Peter Koch: [01:03:27] So OSHA's going to look at it from the perspective of the you're going to have the exposing employer, the controlling employer or the creating employer. So there could be multiple different roles that the employer or the subcontractor can play, depending on what they're doing. So do you own the building and did you hire the subcontractor? Did you create the hazard? Did you expose the employee to the hazard? So there is some liability around there from an OSHA standpoint, depending on what part [01:04:00] you play in. That role from a workers comp standpoint, it's going to come down to who are you employed by? And so if I'm the worker's comp person and I'm insuring the subcontractor and the subcontractor didn't put the or didn't use fall protection, it doesn't matter because they got hurt. It's going to be on my dime and it's going to be something that I'm going to have to manage as the worker's comp carrier between myself and the person that I am insuring from a loss control consultant standpoint. When I'm going out to work with a subcontractor who might be in the business of either roofing or if they're going to do something for a snow removal or maintenance, then my recommendation is you have to protect your employees. So there's two routes for you to go. You can either work with that building owner to provide you with the appropriate fall protection that [01:05:00] fits within the work that you're going to be doing and the workflow that you have to do to maintain safety, quality and productivity, or you bring it yourself and you implement it there. So at the end of that long description, I think the bottom line comes down to not from a worker's comp standpoint, but or even from a worker's comp standpoint, because it helps clarify is to make sure that there's a contract that you describe who's responsible for what within the contract that you have with the subcontractor. So if you're the building owner or the business owner and you're reaching out to a subcontractor, make sure it's outlined in the requirement. Who's responsible for the fall protection and following all of the OSHA rules around fall protection? That would be that'd be my recommendation to one to make it clear and to then to have something to fall back to if there ever is the unfortunate situation where you do have a problem. Peter Koch: [01:05:56] It's been a great conversation so far around fall protection. What I like [01:06:00] to touch on it, just a couple of fringe things that come on to the flat roof discussion here. I almost said flat Earth discussion, but the flat roof discussion, right? So are there any requirements or changes to the requirements around or if there is around roofs size? So if I got a big roof or a small roof, are there any changes around what I need to do for fall protection around roof size, David? David Kozlowsky: [01:06:25] Not per the standard other than the roof size and the amount of equipment on the roof would probably it would do more to limit your options rather than to require a different set of standards. The only deciding factor in 1910.28 is the slope of the roof. And then after that, you know, the larger the roof, the more options you have if you have a small 20 by 20 roof. Obviously, it's going to be hard to stay more than six or 15 feet from the edge at all times. So it just basically would just do [01:07:00] to limit your options. Peter Koch: [01:07:01] That's good. That's a really good point and just a good thing to consider because I want people that are listening to understand that we're talking about the general industry standard 1910.28, not the construction standard where there are some changes if you're doing if you're working as a roofer or doing roof work, actually, there are some roof size requirements in there and we're not going to touch on those. That's going to be a topic for another podcast. So thanks for that clarification. Another one I have are what are the fall protection requirements if I'm actually doing an installation or building, say, an HVAC system on an existing roof. So I'm not maintaining, but I'm not actually building the roof. Are there any differences in what's required for fall protection if I'm doing that kind of activity, either as a subcontractor or as the building owner? David Kozlowsky: [01:07:54] Yeah, so that's basically going to go back to the activity. So [01:08:00] as you were saying before about the liability, the difference between, you know, workers comp and liability. So workers comp is made to cover the employees of the organization. And so basically, the 1910.28 is the general industry standard is I mean, it's not really a perfect correlation, but I kind of like in that towards the worker's comp kind of thing where it applies to the employee. So if you're XYZ company and you're maintaining the roof and your specific employees are up there, that's what 1910.28 is mainly supposed to cover. Not exactly like I said, but mainly once you switch over, like when you said the word construction, you hit the nail right on the head. You're doing roofing construction with, say, building a new HVAC system. Then you really did cross over from [01:09:00] general industry into construction. So the standards that the workers, including the roofers and anybody working on erecting or dismantling the existing HVAC would fall under the construction standard, so they would have to follow that set of rules as far as that's concerned. Peter Koch: [01:09:21] So just making that differentiation, knowing that if I'm building something, constructing something, I'm going to be having to look into that different set of standards. And again, I hate to keep saying this, but there's just so much in this one particular topic on flat roofs for general industry that we don't want to cross too much into the construction side of things. So we'll deal with that in a different podcast. So one more challenge and this happens. Actually, it's happened fairly recently within Maine's history, especially in our wintertime, are skylights and skylights and flat roofs. We've had employees [01:10:00] who are up there doing maintenance, who are up there doing inspections actually fall through a skylight that's hidden underneath the snow or they're not paying attention and they take a step back and they fall into the skylight. So what are the requirements around skylights for flat roofs regarding fall protection? David Kozlowsky: [01:10:20] So the rule of thumb for protecting a skylight can start with the curb height, so the guard rail standard is forty two inches. So in a situation where you might have an architectural skylight that might actually have a forty two inch curb height so that glass doesn't start until you're at forty two inches, and that really becomes a non-issue at that point because you're not. It's not technically part of the walking working surface. Once the glass portion gets lower than 42 whether it be a architectural type skylight or one of the smaller like the dome light type skylights, [01:11:00] then those. I'm just going to come out and say those need to be protected either with a screen or a guardrail. There are limited situations if you have documentation from the manufacturer stating that the glass is rated for, you know, a walk on surface. Basically, if you don't have that documentation from the manufacturer, regardless of however strong you think it might be, then you will need to. You will need to get that protected. If an inspector goes up there and sees a skylight and it's not protected, they're going to ask you for documentation showing that. And if you don't have it, you'll get cited. I've seen it happen a couple of times, actually, especially those the ones that get ignored. Most people pretty much know those little dome skylights, you know, by the time, even if they're new from the factory with whatever pound load on them, by the time they've been up there for 20 years and [01:12:00] they're all faded and cracked. And, you know, I mean, that's pretty self-explanatory. The ones that I see people get dinged on the most is the architectural ones because there are a lot of them have really heavy duty double pane glass, and some of them are designed to be walk on for maintenance and whatnot. And so I see people get dinged on those because they don't have they don't have the paperwork. So if you have paperwork, you're OK. But other than that, you should definitely have a guardrail or a screen of some type over it. Peter Koch: [01:12:33] And then again, the guardrail has to meet those certain certifications or qualifications for strength. And also, I would imagine the screen has to have similar ratings for walk on or fall through, correct. David Kozlowsky: [01:12:47] So basically, the screen kind of it's kind of a little bit different. It's a little bit different application, but the screen falls under protecting a hole, an open hole. [01:13:00] So that's really more what it's like. And the standard for protecting an open hole is that the fall protection, if you don't use a guardrail, whether you use a safety net or some other in a screen, believe it or not, loosely falls under a safety net standard. It's kind of a rigid net if you think about it. So that has to be able to withstand and you're going to have to forgive me because I think I've forgotten the exact number. It's either a three hundred and fifty or a four hundred pound bag of sand dropped from the highest point from which a person may fall, but not less than 42 inches. So in other words, if the nets mounted five feet below the surface, it has to be able to withstand that times. Five feet three. I think it's a four hundred pound is the on site and then three hundred and fifty, I think, is the test weight. But anyway, so then if you're at the walking, working surface or above, the standard says a minimum of 42 [01:14:00] inches. So I believe that most screens would be designed to that four hundred pound bag of sand at forty two inch drop. So that would be the equivalent strength required for that, right? Peter Koch: [01:14:14] Nice. And so again, if you're going to purchase one or you're out looking for to retrofit or to replace, it's easiest actually to go and look for the manufacturer's certifications and qualifications so that you know that it's going to meet those standards. So that's always good to know. You can just even if you go build your own, have your welders fab up something and there are some particular standards that it has to meet. And then you have to prove that you are able that it's able to do that. And when you test it, it can't just be tested at that. It has to be tested beyond what the rating actually is. David Kozlowsky: [01:14:50] Mm hmm. So and you could if you wanted to build your own, I mean, you could. But you would have to either invest in some onsite [01:15:00] testing to make sure you cover it and document it thoroughly or get it, get it engineered. So you'd have to hire a P.E. To come in and do all the calculations and stamp it. I believe OSHA would accept either one of those. I can't say the same for ANSI because they've just kind of gotten a little bit crazy with the requirements, but OSHA would, I believe, accept either one of those, yeah. Peter Koch: [01:15:26] And you know, either way, you want to go, it's. I do find that there's enough suppliers out there and manufacturers out there that can produce something either as a one off. If you have some, some need that doesn't fit what's standard out there or they have enough that will fit some of the standard sizes for your skylights, and it'll be great. David Kozlowsky: [01:15:49] There definitely is, and they're reasonably priced too good. Peter Koch: [01:15:53] All right. So we're getting towards the end of where we are, and I've got one question that I've been wanting to ask you ever since our first podcast [01:16:00] since you have you got tons of creative ideas? You know, I've worked with you. Way back. Well, before we started this podcast, when I first started working for MEMIC, we actually worked together with the client to try to get some flat roof fall protection for snow removal, believe it or not. And the question is, if cost and technology were no issue and I know I mean pie in the sky. But if cost and technology were no issue, what would you create as the perfect fall prevention system for a roof? David Kozlowsky: [01:16:31] Oh, that's so easy because and you really opened that up by saying cost and technology. Yeah, because I we've joked with clients eight million times that the first person to in invent levitation technology was going to become perfect. There's eight million reasons and times when you're on the top of something [01:17:00] and you need to protect yourself from falling off, but there is nothing above you to tie off to. There's no beam or roof or structure of any kind, and you're left constructing this massive support thing to hang a single anchor point over somebody's tank or roof or something that they need to work on. And you could ever invent a levitating anchorage point where you could just hang in mid-air and let somebody tie off too. You would put a whole lot of people out of business? Peter Koch: [01:17:32] You definitely win. I totally thought of that. There's been many times where I'm sitting there going, if I could only have that. And you know what? That's funny because I'm right there with you. If I could, just if I could just not fall, like, take something where I could, if I could step off into space and I'm not going to fall would be perfect. David Kozlowsky: [01:17:48]  Or if you could just or if you could invent a levitating anchor point where you could just bring it above you and just tie off to it like that would be the way to go. Peter Koch: [01:17:58] Or I think that's the  [01:18:00]scouting thing. I remember when I was in scouts, when I first in scouts, they sent me off. I had to go get the left handed and smoke shifter to be able to be attached to the Skyhook. And those were the two things that I searched all over the campsite for, and they never existed, so David Kozlowsky: [01:18:16] They never existed. Peter Koch: [01:18:19] Awesome. So thanks, Dave. That about wraps up this week's Safety Experts podcast. So thank you so much for coming on again and sharing your expertise with our listeners. David Kozlowsky: [01:18:29] No, thank you. I love doing these. It's fun, and I appreciate that you invite me on. Thank you. Peter Koch: [01:18:35] Oh, fantastic. So where can our listeners find out more about Safe Approach in your business and what you do David Kozlowsky: [01:18:42] If you can go on the internet at www.safeapprocah.com? You can email us at David [email protected] or [email protected] or the 800 number 800-471-1157 and we'll be happy to help. Peter Koch: [01:18:58] Perfect. Thanks. [01:19:00] I appreciate it, and thanks for all the listeners out there for joining us today. Today on the MEMIC Safety Experts podcast. We've been speaking about fall protection specifically on roofs with David Kozlowski, president and owner of Safe Approach, right here in Portland, Maine. If you have any questions about fall protection or would like to hear more about a particular topic on our podcast. Email me at [email protected]. Also, check out our show notes at MEMIC.com/podcast, where you can find additional resources, links to other podcasts with Dave, as well as our entire podcast archive. And while you're there, sign up for our safety net blog. So you never miss any of our articles or safety news updates, and if you haven't done so already, I really appreciate it. If you took a minute or two to review us on Spotify, iTunes or whichever podcast service that you found us on, and if you've already done that and subscribe. Thank you because it really helps us spread the word. Please consider sharing [01:20:00] the show with a business associate friend or family member who you think you'll get something out of it. And as always, thank you for the continued support. And until next time, this is Peter Koch reminding you that listening to the MEMIC Safety Experts podcast is good, but using what you learned here is even better.