Steep-Slope Tear-Off With No Fall Protection on a Rain-Softened Site
You are the working owner of a three-person roofing crew in New Bedford. The job is a 44-square tear-off and reroof on a two-and-a-half-story house with a 10:12 pitch, 24-foot eave height, and a 15 mph crosswind. The crew is you, a 19-year-old helper in his third week, and a subcontractor paid by the square. The site is a lawn softened by two days of rain, and the dumpster sits on the driveway. Setup so far: an extension ladder resting against the gutter, extending about 18 inches above the eave, footed on the wet grass; roof brackets with 2x10 planks on the lower slope; workers standing on the planks to strip shingles; bundles staged on the roof above the work area; no harness, lanyard, or anchor on site; no written safety plan or training records. The helper asks whether he has to go up on the plank.
1. Identify the fall-protection and access violations on this site and state the trigger height that applies.
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Trigger. Fall protection is required once a worker is 6 feet or more above a lower level in construction. Both federal OSHA's construction standard (29 CFR 1926.501) and Massachusetts' own fall protection standard at 454 CMR 25.00, enforced by the Department of Labor Standards, key on that 6-foot threshold. At a 24-foot eave nobody on this roof is near the trigger; they are far past it.
Violations. (1) No fall protection system of any kind on a 10:12 roof. Roof brackets and planks are access and work platforms, not fall protection; they do not arrest a fall. (2) Reliance on slide guards or friction, which are not recognized as compliant fall protection. (3) Ladder: it must extend at least 3 feet above the eave or landing, be set at roughly a 4:1 angle, be secured against displacement, and be footed on a stable base. Wet grass under the feet fails that. (4) The ladder-to-roof transition has no grab access. (5) Material handling: bundles staged above the work area create both an impact hazard and a trip hazard on a steep plane. (6) No competent-person oversight, training documentation, or written hazard assessment for a job with this exposure.
The helper's question. The answer is not a shrug. If the plank is the only access provided and no fall protection exists, he should not go up, and you should not send him.
2. Design a compliant approach for this specific roof and schedule, including equipment and rescue considerations.
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Choose the system before the crew arrives. For a 10:12, 24-foot eave, the practical options are: (a) scaffold at the eave with a stair tower, giving a stable work platform for the lower courses and a guardrail; (b) a boom or scissor lift positioned on the driveway for access and material handling; (c) a personal fall arrest system with engineered or certified anchors, independent lifelines, rope grabs, and full-body harnesses, plus a horizontal lifeline designed for the number of workers attached.
Anchor strategy. Anchors must be capable of supporting at least 5,000 pounds per worker attached, or be certified by a qualified person as part of a designed system. On a steep tear-off, installing temporary ridge anchors before stripping begins is usually the cleanest sequence; roof jacks cannot substitute. Keep lifelines clear of sharp shingle edges and keep swing-fall radius in mind.
Access and materials. Reset the ladder on a mudsill or plywood pad, secure it at the eave, and extend it 3 feet above the roof edge or provide a dedicated roof access point. Use a hoist or conveyor rather than carrying bundles up a ladder. Keep staging off the work area and never above workers.
Rescue. Fall arrest without a rescue plan is incomplete. Have a ladder or lift available for assisted rescue, a means to reach a suspended worker within minutes, and a designated person who knows the procedure. Document training for all three workers, including the subcontractor, and hold a start-of-shift briefing on the roof plan, wind, and wet conditions. If conditions degrade, stop.
3. The subcontractor says fall protection is the general contractor's problem and keeps working. How do you respond, and what are your obligations as the owner?
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The duty does not transfer by assertion. As the owner and the person directing the work, you have a general duty to provide a workplace free of recognized hazards, and you control the site. A subcontractor who is exposed to a fall hazard must be protected, and you cannot contract that away. If the sub is genuinely an independent business with its own employees, they still owe their workers protection, and you still owe a hazard-free site for the work you commissioned. Practically, you should treat this as a stop-work issue.
Immediate steps. Stop the work in that area, remove the crew from the roof, and document the instruction in writing with a time and date. Require the sub to provide a written fall-protection plan and proof of training and insurance before returning. If he refuses, remove him from the site and document the termination for cause. Do not let the helper fill in on the plank to keep the schedule; that converts a subcontractor problem into your liability and puts the least experienced person in the highest hazard.
Records and insurance. Confirm workers' compensation coverage for everyone on site, including the sub's employees, and confirm your own liability coverage responds to subcontracted work. Keep the training records, the hazard assessment, and the daily briefing log. If an injury occurs, the absence of these records is what turns a bad day into an uninsurable one. Finally, tell the helper plainly that he can refuse the task, and that no schedule pressure changes the answer.