Standard Interpretations - Table of Contents|
| Standard Number:||1926.502(f)(1); 1926.502(f)(4); 1926.502(h)(2)|
|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.|
"...their use does not require employees to move backward. In addition, they are light in weight and therefore develop little momentum. Wheelbarrows and mopcarts do not present the same degree of risk to roofing employees as do such machines as felt layers and gravel buggies. (Cf. Ex. 2:36, 120, 152). Mopcarts and wheelbarrows do not require employees to divide their attention between the equipment they are using and the roof edge, as they would have to do with heavier, more awkward machinery."Question 3: What are the hazards associated with operating mechanical equipment while doing roofing work?
"...the greatest hazards with mechanical equipment operation are at the points of turn-around (perpendicular to the direction of equipment movement) where an employee's attention is no longer on the edge [fall] hazard, but rather is on the effort required to turn the equipment around (cf. Ex. 2:82, 120, 191). At these points, employees are in danger of losing their balance because of the sometimes awkward motions necessary to turn the mechanical equipment, and because of the need to step backward toward the edge, as they try to line the machine up for the next run."Question 4: What OSHA regulations address the use of mechanical equipment during roofing work in construction?
When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge.1926.502(f)(1)(ii):
When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction of mechanical equipment operation.1926.502(f)(4):
Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system.1926.502(h)(2):
Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low sloped roofs.On May 19, 1998, OSHA issued an interpretation memorandum (Wiehrdt memo, attached) that allows a portion of a piece of mechanical equipment (the hose and roller/wand) to be used outside of a warning line and in areas with only a monitor present. Using the hose and roller is not considered any different from using a broom or mop to spread glue in areas protected by a monitor, which is allowed by the standard. However, the wheeled, pressurized storage tanks of the machine were considered to present the same hazard as mechanical equipment for the following reasons:
|Standard Interpretations - Table of Contents|