Roofing Suppliers and OSHA Fall Protection

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"Question: I am a supplier of roofing materials. I deliver roofing materials to the job and place the material on the roof. What are my obligations?

Answer: Because your product will be used during construction activity, you are required under Subpart M to protect your employees from falls of 6 feet or more to lower levels when possible. Therefore, employees must be provided with personal fall arrest equipment to attach to an anchor point if available. In the case of vendors delivering roofing materials, OSHA will require the following:
Gaining Access to the Roof: A handhold (rope, chain, or other railing) must be attached to the conveyor belt so that the employee has something to steady himself with as he gains access to the roof or a ladder must be used to gain access to the roof.

Distributing the Roofing Materials: Once on the roof the vendor's employee will receive the roofing products from a conveyor belt (lift truck or similar equipment) and then distribute the products onto the roof at various locations. During this distribution process, OSHA will not require the vendor's employees to install an anchorage point for fall protection equipment regardless of the slope off the roof or the fall distance."
 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23883

Trenton H. Cotney
Board Certified in Construction Law
Trent Cotney, P.A.
1207 N Franklin St, Ste 222
Tampa, FL 33602
(813) 579-3278

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