Thursday, January 30, 2014

From our friends at Fall Protection Blog comes a nice article on warning lines.  As most of you have been able to see over the years, these lines are readily ignored.  Given our knowledge of human nature, can we then assume that the warning line is enough?  

When is a Warning Line Sufficient Fall Protection?

When is a Warning Line Sufficient Fall Protection?

There is one quick and simple answer to the question, “When is a warning line sufficient fall protection?”


To be clear, that does not mean that a warning line does not have its applications or that it does not, at times, achieve regulatory compliance, but it certainly will never serve as fall protection.  The best a warning line system is going to do is keep you in an area that prevents you from being exposed to a fall – if set up properly.  The problem is that warning lines are not always set up properly.  Sometimes, they are placed directly at the edge of a building.  Should somebody stumble, there’s nothing a warning line at the edge of the building is going to do to stop them from falling.

Proper Warning Line Practices

Let’s focus on when a warning line is acceptable and how it should be properly set up to eliminate fall exposure.  Warning lines are most often associated with roof work.  That is because, for the most part, that’s where their use is allowed – specifically low-slope roofs (4 to 12 or less, vertical to horizontal).  This does not mean HVAC guys working on a roof or electricians or other maintenance personnel, this means roofing work:  the actual laying, tearing up, or repairing of roof membrane.

For all other type of work that happens to take place on a roof, proper fall arrest or prevention must be utilized – as far as the regulations are concerned.  However, as safety professionals, it is important to go beyond the regulations to ensure that other criteria have not been established by letters of interpretation.  In this instance, some have.  The most recent can be found here: Use of a warning line instead of conventional fall protection; Part 1926 Subpart M.

This letter reiterates the fact that only roofers can utilize a combination of warning line and safety monitor (to be discussed further below).  All others, even in situations where they may be working alongside roofers, must use conventional fall protection or prevention means.  OSHA states that no distance from the edge is a “safe” distance, however, they will consider a warning line for work other than roofing work a de minimis violation if:

  • It meets all of the requirements of 1926.502(f)(2)

  • It is set 15’ from the edge

  • No work is to take place between the warning line and the roof edge, and

  • A work rule is established to ensure nobody leaves the confines of the warning line

The Necessity of the Safety Monitor

Now that we’ve clarified the exception to the rule, let’s look at the rule itself.  A warning line is acceptable in certain roofing situations on low slope roofs.  One of the most overlooked parts of this regulations is, in my experience, that a warning line alone is unacceptable.  It must be used in conjunction with a safety monitor, rails, nets, or personal fall arrest systems.  The regulations actually allow for the use of only a safety monitor in one situation (a roof 50-feet or less in width) but make noallowance for the use of warning lines alone.  Even when a company remembers to include a safety monitor, the monitor is often unacceptable because they are doing other work that takes them away from their monitor duties or they cannot readily communicate with or see everybody on the roof.  Companies sometimes find it very difficult to pay a person to “do nothing”, but as a safety professional it is important to get that company to understand that not only are they required to do it, but that the worker is actually (or SHOULD actually be) doing something: actively monitoring the workers for unsafe situations.

In addition, warning lines must be set up at least 6’ from the edge on all sides of the work.  Should mechanical equipment be in use, then the line must be 10’ from the edge which is perpendicular to the equipment’s line of travel.  In other words, if your equipment is heading toward an edge, the line must be 10’ back from that edge.

Working Beyond the Line

If you’ve got adjacent support areas that are not directly inside your work area, they must be connected to your work area by a path made of two warning lines.  At no time should your workers be walking on a roof with no warning line between them and an edge, unless they are the workers specifically designated to work between the warning line and the edge.  At one time, it simply may have been acceptable to say that there was no way a worker performing roofing work at the edge of a roof could have fall protection, but there is so much technology available today that this is often not the case.  There are free-standing rails, parapet clamp rails, weighted stands, and fall protection carts available that should be put into use whenever possible.  Of course, not all situations have a solution, which is why the regulation allows for a roofing worker to work outside of the warning line without any means of fall protection.

Warning Line Criteria

Your warning line, itself, must also meet certain criteria.  You cannot just spray-paint a line on the ground, for instance.  A warning line must consist of ropes, wires, or chains with supporting stanchions.  The line must be flagged with high visibility material every 6 feet or less and must remain completely between 34” and 39” from the walking/working surface.  The stanchions must be able to withstand being tipped by 16 lbs. of pressure 30” off the walking/working surface and the line must have a minimum tensile strength of 500 lbs.  The line must also be attached in such a way that pulling it in one section does not affect other sections.

As you can see, there is a lot to consider, yet so many times a warning line is thrown up as a dog-and-pony show.  Perhaps these contractors don’t really understand the rules.  Perhaps they do, but feel that nobody is going to bother to come up to check on their setup.  Regardless of the reason, their employees are in an equal and very real amount of danger.

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