Cal/OSHA recently adopted Section 1731, Article 30 of the Construction Safety Orders. The new rule lowers the residential roofing fall protection trigger height from 20 feet to 15 feet with roof slopes 3:12 or greater. It applies only to roofing work on new production-type residential construction (any new residential housing unit that is not a custom-built home). It is not proposed to apply to custom-built homes, re-roofing operations, roofing replacements or additions to existing residential dwelling units. The new rule is available at www.dir.ca.gov/Title8/1731.html.
The trigger height is now consistent with the rules for residential framing (Section 1716.2, Article 29). The new rule provides a single uniform 15-foot trigger height for the majority of work performed during the early phases of production-type residential construction work; i.e., during framing and roofing operations. This simplifies the regulations and makes it easier to comply with fall protection requirements during the beginning phases of construction.
The new requirements apply to roofing work such as loading and installation of roofing materials, including related insulation, integral roofing system sheet metal, and vapor barrier work. The new trigger level does not apply to the construction of the roof decking (plywood, tongue-and-groove boards, or hardboard underlayment for roofing materials).
Cal/OSHA made this change in the rule because they noted a significant decrease in injuries when the same trigger level change was made in the framing rule. The old roofing trigger height applied to buildings three stories or higher. With the rising cost of land and a trend toward higher ceilings and rooflines in California homes, it is becoming more common that two-story residential homes are reaching the 20 foot trigger level. This change was made to protect workers from more frequent and higher roofline hazards.
There are two tiers of fall protection requirements for construction:
Where the roof is sloped 3:12 through 7:12 and the eave height exceeds 15 feet above the grade or level below, employees must be protected by one or any combination of the following:
Where the roof slope is steeper than 7:12, regardless of the height, workers must be protected by one or any combination of the following:
The new section requires more training on fall hazards for roofing workers in order to supplement the Illness and Injury Prevention Program (IIPP). It requires training on the industry-specific hazards in new production-type residential roofing activities. The hazard-specific training should include, but is not limited to:
The above evaluations and/or recommendations are for general guidance only and should not be relied upon for legal compliance purposes. They are based solely on the information provided to us and relate only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.
