Fall Protection for Residential Solar Installation

[BroverCleveland]

Hey all,

I've been in the solar industry for 10+ years now, and have always run into this same issue. On a ranch style home (or any roof that is between 6' and 18.5' from grade), fall arrest is not usually compatible because you don't have enough vertical height to allow the fall arrest equipment to deploy, meaning you'll hit the ground before your PFAS does it's job. The calculation varies, but the gist assumes a 6' tall worker, 6' lanyard, 3.5' deceleration distance, and 3' safety factor; this would require an 18.5' roof edge height from grade for Fall arrest to be used. I've seen different calculations that result in a 14' minimum height too.

We have historically used a combination of fall positioning and fall restraint. We use static climbing ropes and rope grabs with a harness that has a belt d-ring, and the policy is that when you first scope out your work area, you carefully descend down to the lowest point you'll work from, keeping tension on the rope, and then tie a temporary knot below the rope grab (have already confirmed with the rope manufacturer that we use, this is not an issue). This now creates a physical block that would prevent our employees from ever reaching the fall hazard. Additionally, we require that anytime we are working on the roof, that the rope must always be under tension, meeting the fall positioning requirements of no more than 2' of free fall.

Guardrails, safety nets, mobile fall arrest trailers, etc. are usually too expensive to buy/rent and time consuming to setup/take down.

We recently received feedback from a third party fall protection training company that we should be using a backup fall prevention method in addition the one described above. Fall Arrest isn't always feasible, and adding another fall positioning/restraint system seems like a headache, and could potentially cause more of a tripping hazard by having the roof littered with ropes. Leading Edge SRL's are certainly an option, but would need multiple sizes per employee depending on the size of the roof. That said, I've heard of other solar companies that utilize SRL's then having to deal with employee back injuries. The SRL is constantly pulling you up the roof, so you are constantly fighting it, resulting in back strains/injuries.

I'm sure solar isn't the only trade that experiences this, but then again, OSHA doesn't seem to care much about roofers or iron workers, as much as they do about anybody else working at heights. I just find it difficult to believe that there's not a solution that doesn't also injure people from using it to protect themselves against injury (LE SRL's).

What I'm wondering is, has anybody found a solution that works for most residential roofs that doesn't cost an arm and a leg to purchase or setup? Is the recommendation from the third party overkill? My strategy has always been to find a system that works with the majority of situations and to provide routine training on how to use the equipment we have to prevent accidents. We have a hierarchy of who is qualified and approved to install safety anchors, and we do monthly PPE inspections (OSHA requires every 6 months, but shingle roofs are HARD on PFAS). We also do monthly surprise site safety audits, and reward our teams for working safely.

 

[jaggedben]

I'm reading between the lines here a bit, but it sounds like you may be using a fall restraint system that isn't actually rated as a fall arrest system. (I'm mainly going off the belt D-ring description. A fall arrest system would typically have a back d-ring or two side d-rings.) If that's the case I would probably recommend changing to proper fall arrest harnesses and otherwise continuing your diligent practices. Adjusting the rope grab and knot to eliminate or reduce the distance that one could fall off the roof, as you are doing, is certainly essential. It's how I've always been trained and how I've always trained people, and cannot be emphasized enough. It's required to still qualify for fall arrest, and it also effectively turns your fall arrest system into a fall restraint system with a level of fall arrest backup. That is, if the rope grab height is adjusted imprecisely but not too imprecisely, you still have adequate fall arrest (with the level of acceptable imprecision dependent on the height of the building). But if the harnesses you're using aren't proper fall-arrest equipment, then you risk greater injury if/when someone fails to adjust the rope grab correctly, thus losing their fall-restraint protection and having no backup. That could include failure of the harness in a fall, or greater risk of injury post fall (e.g. suspension trauma or head trauma from not being held upright). Consider that with either system the likelihood of improper setup is the same, but the severity of injury with improper setup is reduced with proper fall arrest harnesses.

If I'm misunderstanding, and you are already using proper fall arrest equipment, then I think the third party recommendation is probably overkill, or there is some other element that isn't coming through here. (Or, to the extent their recommendation didn't involve an actual product or group or type of product to use, it wasn't exactly a bona fide recommendation.)

 

[ramsy]

fall arrest is not usually compatible because you don't have enough vertical height to allow the fall arrest equipment to deploy

Boom lift with suspended cable for fall protection lanyards, and perhaps dual use for light material pallets when needed.

 

[BroverCleveland]

I'm reading between the lines here a bit, but it sounds like you may be using a fall restraint system that isn't actually rated as a fall arrest system. (I'm mainly going off the belt D-ring description. A fall arrest system would typically have a back d-ring or two side d-rings.) If that's the case I would probably recommend changing to proper fall arrest harnesses and otherwise continuing your diligent practices. Adjusting the rope grab and knot to eliminate or reduce the distance that one could fall off the roof, as you are doing, is certainly essential. It's how I've always been trained and how I've always trained people, and cannot be emphasized enough. It's required to still qualify for fall arrest, and it also effectively turns your fall arrest system into a fall restraint system with a level of fall arrest backup. That is, if the rope grab height is adjusted imprecisely but not too imprecisely, you still have adequate fall arrest (with the level of acceptable imprecision dependent on the height of the building). But if the harnesses you're using aren't proper fall-arrest equipment, then you risk greater injury if/when someone fails to adjust the rope grab correctly, thus losing their fall-restraint protection and having no backup. That could include failure of the harness in a fall, or greater risk of injury post fall (e.g. suspension trauma or head trauma from not being held upright). Consider that with either system the likelihood of improper setup is the same, but the severity of injury with improper setup is reduced with proper fall arrest harnesses.

If I'm misunderstanding, and you are already using proper fall arrest equipment, then I think the third party recommendation is probably overkill, or there is some other element that isn't coming through here. (Or, to the extent their recommendation didn't involve an actual product or group or type of product to use, it wasn't exactly a bona fide recommendation.)

My understanding of the OSHA requirements was that fall arrest systems and restraint systems are different. An arrest system allows you to fall, and softens the blow, where as restraint/positioning systems don't allow the fall in the first place (from OSHA 1910.140(b)). As I'm re-reading 1926.501, and 1910.140, I'm starting to wonder if I'm misinterpreting something. 1926.501(b)(1) states "Unprotected sides and edges. Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems." 1910.140(c) states "General requirements. The employer must ensure that personal fall protection systems meet the following requirements. Additional requirements for personal fall arrest systems and positioning systems are contained in paragraphs (d) and (e) of this section, respectively." This seems to lump positioning and arrest in the same category though, and more importantly uses the term "personal fall protection systems" vs "personal fall arrest systems." Too much nuance?

I used to (in the good ole days) use a shock lanyard attached to my dorsal, and pass it through my legs to work on steep roofs, but this puts constant tension on something that isn't supposed to have constant tension, and will release with the right amount of force. The harnesses we use have dorsal d-rings, side d-rings, and belt d-rings. If the harness has no belt d-ring, we uses spreader bars to connect the two side d-rings, and have a nice central place for the rope grab to go. We chose this method so we can use it on low pitch and steep pitch roofs (where you can't physically stand without rope support).

 

[BroverCleveland]

Boom lift with suspended cable for fall protection lanyards, and perhaps dual use for light material pallets when needed.

Certainly an option. Impractical for our smaller jobs; we'd price ourselves out of every project under 10kW.

 

[jaggedben]

My understanding of the OSHA requirements was that fall arrest systems and restraint systems are different. An arrest system allows you to fall, and softens the blow, where as restraint/positioning systems don't allow the fall in the first place (from OSHA 1910.140(b)). As I'm re-reading 1926.501, and 1910.140, I'm starting to wonder if I'm misinterpreting something. ...

I admit to not being super familiar with the precise wording or interpretations of the requirements, but nothing I see in the provided indicates that personal fall arrest systems and restraint or positioning systems are mutually exclusive. You could use a fall arrest system to provide restraint or positioning if that system meets all the relevant requirements. I don't know why the third-party consultant would have told you that you need a backup fall-arrest system unless the system you are using for travel restraint doesn't qualify as a fall arrest system.

 

[BroverCleveland]

I admit to not being super familiar with the precise wording or interpretations of the requirements, but nothing I see in the provided indicates that personal fall arrest systems and restraint or positioning systems are mutually exclusive. You could use a fall arrest system to provide restraint or positioning if that system meets all the relevant requirements. I don't know why the third-party consultant would have told you that you need a backup fall-arrest system unless the system you are using for travel restraint doesn't qualify as a fall arrest system.

The only reason I would think it wouldn't qualify as a fall arrest system, is because it's not designed to arrest a fall, it's designed to prevent the fall in the first place. I think that's where the exact wording of "personal fall protection system" and "personal fall arrest system" come into play. from 1910.140:
"Personal fall arrest system means a system used to arrest an employee in a fall from a walking-working surface. It consists of a body harness, anchorage, and connector. The means of connection may include a lanyard, deceleration device, lifeline, or a suitable combination of these.

Personal fall protection system means a system (including all components) an employer uses to provide protection from falling or to safely arrest an employee's fall if one occurs. Examples of personal fall protection systems include personal fall arrest systems, positioning systems, and travel restraint systems."

 

[jaggedben]

As stated in those definitions, personal fall arrest systems are a subset of personal fall protection systems. All personal fall arrest systems are personal fall protection systems, but not all personal fall protection systems are personal fall arrest systems.

Whether the system you're using is designed to be a personal fall arrest system should be answered by the manufacturers documentation.

The fact that you might use a personal fall arrest system for restraint or positioning, (which to my understanding is never a bad idea) does not by itself disqualify it's use a personal fall arrest system. It can be both at the same time. It can even provide restraint with respect to one roof edge and arrest with respect to another roof edge simultaneously.

 

[BroverCleveland]

As stated in those definitions, personal fall arrest systems are a subset of personal fall protection systems. All personal fall arrest systems are personal fall protection systems, but not all personal fall protection systems are personal fall arrest systems.

Whether the system you're using is designed to be a personal fall arrest system should be answered by the manufacturers documentation.

The fact that you might use a personal fall arrest system for restraint or positioning, (which to my understanding is never a bad idea) does not by itself disqualify it's use a personal fall arrest system. It can be both at the same time. It can even provide restraint with respect to one roof edge and arrest with respect to another roof edge simultaneously.

If I look at 1910.28 I would think that the requirement from OSHA is for a fall protection system (as opposed to a fall arrest system specifically), which under 1910.28(b)(1)(i)(C) states, "Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems." I think the key word I'm digging into is, "or" here. It seems like as long as you have one of those systems, you're OSHA compliant. Is that how you'd interpret that? Again, I'm asking, because I think I'm finding numerous areas of OSHA requiring different things. As stated above In 1926.501(b)(1) "Unprotected sides and edges. Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems."
This next question might be the stupidest question I ask, but is there any merit to the order in which OSHA is read? I.E. since 1910.28 comes before 1926.501, does 1926.501 trump the earlier code? or is it the other way around?

 

[tburdick]

Maybe you should look into a retractable or "yo yo" fall arrest.
Or contacting OSHA.
They will help you figure it out safely.

 

[BroverCleveland]

Maybe you should look into a retractable or "yo yo" fall arrest.
Or contacting OSHA.
They will help you figure it out safely.

Definitely considered SRL's. We've gotten some feedback from some seasoned installers who referenced back injuries increasing when they switched to SRL's. Constantly fighting the retracting part, and would need a few different sizes for each installer.

Here is an OSHA response letter (from 1995) that confirms that a restraint system can be used in lieu of fall arrest, insinuating that it does something that a fall arrest system does not: prevent the fall from happening. Looking at the hierarchy of fall protection, restraint is more favorable than arrest. It seems like since 1995, OSHA has made it more clear (if I understand the OSHA regs correctly) that a personal fall protection system is required, and that a personal fall arrest system, fall restraint system, positioning system, guardrails, etc. are all categorized as a personal fall protection systems, but you only need to provide one of them.

Does anybody know if a later code in OSHA would negate an earlier one? I.E. if an earlier code references the need for a personal fall protection system, and the later code requires a personal fall arrest system, which one is correct?

 

[jaggedben]

Definitely considered SRL's. We've gotten some feedback from some seasoned installers who referenced back injuries increasing when they switched to SRL's. Constantly fighting the retracting part, and would need a few different sizes for each installer.

Here is an OSHA response letter (from 1995) that confirms that a restraint system can be used in lieu of fall arrest, insinuating that it does something that a fall arrest system does not: prevent the fall from happening. Looking at the hierarchy of fall protection, restraint is more favorable than arrest.

I would probably agree, but I'd also say an arrest system used to provide restraint is at the top of the hierarchy.

It seems like since 1995, OSHA has made it more clear (if I understand the OSHA regs correctly) that a personal fall protection system is required, and that a personal fall arrest system, fall restraint system, positioning system, guardrails, etc. are all categorized as a personal fall protection systems, but you only need to provide one of them.

Does anybody know if a later code in OSHA would negate an earlier one? I.E. if an earlier code references the need for a personal fall protection system, and the later code requires a personal fall arrest system, which one is correct?

The later code would be the one you have to follow. Or more precisely, the one that is presently in force.

 

[TVH]

Employ a Fall Protection Specialist/Engineer to evaluate your situation.
Start with an internet search. Review qualifications.