Twenty-Two Feet of Eave at 9/12
You own a small crew reroofing a two-story, 32-square house with a 9/12 pitch. The eave is 22 feet above grade on the low side. Your four-person crew has two harnesses, two six-foot shock-absorbing lanyards, no roof anchors, and one 28-foot extension ladder. The homeowner offers to let you tie off to a chimney that is scheduled for demolition next week, and asks that you not "put holes in the new roof." One worker says that because this is a house and not a commercial building, fall protection does not apply. Work starts Monday at 7 a.m. and the material drop is Friday.
1. Is the roofer correct that residential work is exempt, and what does the standard actually require at this pitch?
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He is wrong, and the belief is a decade out of date. The old residential interim guidance was rescinded in 2013; residential steep-slope work now requires conventional fall protection like any other.
For a roof steeper than 4/12, the employer must provide one of:
- Guardrail system with top rail, midrail, and toe board, or
- Safety net system, or
- Personal fall arrest system.
A safety monitoring system is not an option here - it is a last resort permitted only where the employer can demonstrate that conventional means are infeasible, and it does not apply to steep roofs. With a 22-foot eave, a fall is fatal, not a close call.
Also note what does not count: the chimney. It is being demolished, its condition is unknown, and it is not an engineered anchor. Anchors must support 5,000 pounds per employee attached, or be designed by a qualified person with a safety factor of at least two.
2. Design a workable system for four workers on this roof, including how you handle the homeowner's "no holes" request and the 22-foot eave.
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Work the problem in three layers.
1. Clearance math first. A six-foot shock-absorbing lanyard needs roughly: 6 ft lanyard + 3.5 ft deceleration + 1 ft harness stretch + about 5 ft from D-ring to feet + 3 ft margin ≈ 18.5 ft of clearance below the anchor. If a worker at the eave is already 12–15 ft below a ridge anchor along the slope, a lanyard system anchored at the ridge arrests him at or below grade. So the anchor height, not the harness, decides the design. Use self-retracting lifelines or an engineered horizontal lifeline positioned so the math closes, or put guardrail at the eave and treat PFAS as the backup.
2. Anchor strategy. Manufactured ridge anchors installed per the manufacturer's instructions and sealed at each fastener, one per worker on independent lifelines - that answers the "no holes" objection in a way the customer can accept. Roof jacks with planks and guardrail at the eave is a legitimate alternative on a 9/12.
3. Access and rescue. The 28-foot ladder needs to extend about 3 ft above the 22-foot eave and be set at roughly a 4:1 base ratio, secured at the top. Write a rescue plan: a worker unconscious in a harness after an arrest has minutes, not hours, before suspension trauma. Train two people on the crew to execute it.
If the customer will not accept anchors, the job does not start. No waiver protects you from a citation or from his family.
3. The homeowner refuses anchors outright and says he will sign anything you put in front of him. Your crew is already scheduled and the material ships Friday. What is your decision?
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You decline or you find a system that needs no penetration - and you never let a homeowner sign away a duty you owe to your own employees.
- The duty is yours, not his. The employer controls the means and methods. A homeowner's signature creates no defense to an OSHA citation and no defense in a wrongful-death action.
- Alternatives exist. Free-standing counterweighted guardrail at the eave, scaffold at the low side, or a horizontal lifeline over temporary ridge boards removed at completion. All are purchasable and all can be priced into the bid line by line.
- Commercial reality. Anchors and lifelines on a 32-square steep roof are a few hundred dollars of hardware against a five-figure contract. If a customer's aesthetic objection is worth more to him than your crew's lives, he is not your customer.
Document the conversation, reschedule the drop, and move to the next job. The exam wants to see that the safety obligation is non-delegable and non-waivable.