Embracing safety

In the roofing industry, there is a myth that productivity and safety cannot coexist—that one occurs only at the expense of the other. This notion creates competition ­­­between the two, and safety rarely wins. Because of that notion, there are many roofing company owners who simply don't understand safety.

However, many contractors also have experienced fewer lost-time incidents and lower insurance and legal costs, as well as improved their companies' long-term profits, as a result of safer work sites. The belief that safety is integral to a company's success is increasingly being accepted. But for a company to fully embrace safety, it must develop and implement a comprehensive, effective safety program.

Roofing is dangerous

We all know roofing work can be dangerous, and I haven't met a worker, foreman or contractor without a story about someone falling, being burned, injuring his or her back, or worse. Nevertheless, many experienced roofing workers think they've seen it all and know how to work safely without following a company safety plan. But industry statistics prove otherwise.

The Bureau of Labor Statistics tracks work-related incidents, such as accidents and deaths. The Occupational Safety and Health Administration (OSHA) and other groups rely heavily on the bureau's statistics to gauge safety performance in various industries. Consider the most recent roofing industry statistics shown in the figure.

Roofing industry statistics from the Bureau of Labor Statistics

Although the numbers of cited fatalities in the roofing industry may not seem that high in relation to the total number of people working on roofs, it is important to note roofing-related fatalities are among the highest in the construction sector.

Also, though there was a decline in such fatalities in 2008 compared with 2007, the number of deaths increased again in 2009 despite a decrease in overall production. The increase has been attributed to possible worker fatigue resulting from overtime (because of increased layoffs) and workers taking more risks because they are worried about unemployment.

And, according to a study by the National Council on Compensation Insurance Inc., "Workplace Injuries and Job Flows," economic recoveries tend to see a spike in on-the-job accidents and workers' compensation claims because of increased hiring of inexperienced workers. Preparing returning or newly hired workers for rooftop safety is vital to stemming that trend.

OSHA requirements

When I teach NRCA's Profitability Through Effective Safety Programs, I ask the students whether OSHA requires employers to have company safety programs. Almost all respond "yes." And when asked why they believe that to be the case, a majority say they just assume it makes sense. But when asked whether they have one in place for their companies, most say, "Well, nothing formal."

The fact is federal OSHA does not require a company safety program. But it does say in its Safety and Health Regulations for Construction at 29 CFR 1926.20(b)(1): "It shall be the responsibility of the employer to initiate and maintain such [safety] programs as may be necessary to comply with this part."

Additionally, 29 CFR 1926.21(b)(2) states: "The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards."

Despite there being no OSHA mandate for company safety programs, the agency clearly requires companies to develop programs that ensure employees understand and comply with the agency's established safety regulations. However, a number of states that manage their own occupational safety and health rules, such as California, Minnesota and Washington, do have requirements for written programs that seek to reduce injuries through an established safety and health management system.

In California, for example, employers are required to establish written injury and illness prevention programs (IIPPs). According to recent comments made during the OSHA Advisory Committee on Construction Safety and Health meetings, Cal-OSHA's IIPP rule initially was perceived to be a requirement that would be difficult for employers to comply with and add nothing more than a paperwork burden. After about 20 years of existence, the opposite has happened—IIPPs are commonplace, and employers have reported positive effects from such programs.

Federal OSHA now is considering promulgating its own national safety program standard.

Safety program components

The best way to ensure your employees work safely and understand and comply with OSHA's established safety regulations is by establishing a company safety and health management program. Several components are necessary to ensure your safety program is effective.

First, assessing your policies and procedures is important; in particular, are they in line with your company's mission statement? If you advertise, for example, "Sky-High Roofing, where safety is our No. 1 priority," do your safety policies and procedures reflect that public statement?

Each year, you should establish annual goals to work toward throughout the year. Talk to your insurance broker and loss-control representative for input.

In addition, it is vital that you establish a safety budget. The budget should include all safety meetings, incentive gifts, time employees spend in training (including toolbox talks), safety equipment needs (new and anticipated) and anything else safety-related.

Some companies' safety budgets even include funds for possible OSHA fines. However, be careful not to give the impression that fines are a foregone conclusion—that may lead to a defeatist attitude among workers. If you don't have to pay any fines, those funds can be carried over and used as an incentive pool for the following year.

Budgeting for safety is important because it communicates to everyone safety is a priority. It should be included as overhead, spread across all your company's projects and included in proposals.

Once you've established your policies and procedures, you need to ensure they're understood and carried out by your work force. It's best to have several formal meetings in which you communicate your safety program's tenets, its importance to the company's success and your commitment to a safe work environment. You can do this through annual companywide safety meetings and semi-annual or quarterly update meetings.

In addition, establish a formal safety orientation program for new employees. This way, new employees learn from the outset not only how important safety is to your firm but what they can do to be safe.

Formal safety training should flow into informal training efforts, which include all your safety-specific training—any training regarding fall prevention, back injury prevention, etc. These programs can be held monthly or bimonthly and can include videos, demonstrations, programs from vendors, online offerings, etc.

Informal training then should be reinforced by on-the-job training efforts, which primarily should include toolbox talks. However, it's also important to include discussions as a result of safety audits, weekly inspections and the like. I encourage the use of mentoring; whether you have experienced crew members teach new employees the correct procedures or have them help with demonstrations, it's a great way to include and show you value your experienced workers.

Safety committees

Part of the risk management process (see "Risk management," page 70) is to review or follow up implemented procedures. The way to begin the follow-up process is with a safety committee. Only with the involvement of all levels of your company can you achieve unanimous commitment and dedication to safety. Otherwise, safety becomes the responsibility of solely a company's safety director and owner.

An effective safety committee will comprise at least four levels in the organization: owner, senior manager, middle manager and field representative. I suggest having a committee include six people. The two additional participants could be an estimator and another foreman or field worker.

If the committee is composed of six people each serving six-month terms, stagger their terms so each month one person goes off the committee and a new person comes on. In a person's sixth month, he or she will chair the meeting.

This rotation gives everyone a chance to lead the safety discussion and is vital to communicating to your staff your commitment to the safety program. You want to create an environment where all employees feel comfortable reporting what is working and not working. This is a great opportunity to encourage and empower your employees to challenge current practices, ask for help and provide feedback.

Although many roofing companies have safety directors, a safety director should not be directly responsible for safety but rather facilitate the safety process. Having a safety committee in place will ensure a safety director is used most effectively.

As a facilitator, the safety director's role can include:

  • Keeping the current safety chairman on task by assisting with agenda development, following through on action items, budget maintenance, taking/distributing minutes and accident investigation reporting
  • Creating a budget draft
  • Coordinating training—setting up all safety meetings; arranging for speakers, demonstrations, etc.; and being a trainer in some instances

Management commitment

A safety program will never fully work without management commitment; otherwise, the nonverbal message to staff is that safety is conditional. A company's safety program is successful when the established policies and procedures are actually enforced in the field.

For example, if a policy says all workers must wear goggles when disposing of tear-off material in a chute and you see a worker put on goggles just before tipping a load, your program is working.

If that does not occur, the program needs to be evaluated to see where the breakdown is. It may just mean the employee broke the rule, but it's important not to fall victim to the blame game. Sure, he may not have put the goggles on, but why? Was he being rushed? Did he know the rule? These are matters the safety director needs to gather for safety committee deliberation.

Where do you start?

After discussing this information during Profitability Through Effective Safety Programs, I always ask students: "What is your gut reaction to all this?" Without fail, someone always says the process seems overwhelming.

This reaction is reasonable and understandable. I suggest establishing your safety program during a five- to seven-year time period. It simply cannot happen overnight or in six months or even a year. You can begin by doing two things: establishing a safety committee and conducting toolbox talks.

The safety committee will take charge of the messaging and buy-in, and the toolbox talks convey the critical safety tips to those who make safety happen: the crews.

The safety committee's first role (after making sure the toolbox talks are being conducted) is to do a job task or job hazard analysis (risk identification). This effort yields your safety policies and procedures. Once you do this, the rest of the program will start filling in. The safety director's role is to keep everyone on track and moving forward. The bottom line: A safety program's ultimate goal is to identify, teach and reinforce desired behaviors.

Once you see employees improving their safety practices as a result of your safety program efforts, you will be better able to respond to other projects with ease. And in these times of keen competition, wouldn't it be great to know your company and employees are safe?

Thomas R. Shanahan, CAE, is NRCA's associate executive director of risk management.

Risk management

Many companies take on more risk during a downturn for survival reasons and can risk their employees' and company's existence, whether by exposing workers to unknown hazards or signing contracts with clauses that are patently unfair but completely legal—putting the business' viability at stake should anything go wrong.

To avoid this, consider implementing a five-component risk management process that includes the following:

  1. Risk identification
  2. Risk analysis
  3. A risk management strategy
  4. Implementation
  5. Review

Risk identification

Identification is the most important part of the risk management process because what you don't identify, you automatically absorb.

For example, say you take on a job where you discover asbestos is present. Because you had no idea you will need to manage or possibly abate the hazard, you take on a multifaceted risk that could be costly.

Risk analysis

In the second step, risk analysis, you should estimate the effects of a loss on profitability, safety and your company mission. Part of those effects are the costs associated with the risk.

Direct costs are relatively predictable; for example, assume you are working on an asbestos roof removal job for a school. You know what it will cost to follow the regulations and properly dispose of asbestos-containing roofing materials (ACRM), but indirect costs or consequential losses are tougher to predict and quantify.

It's important to speak with your insurance broker and loss-control advisers or anyone else who may have expertise in the risk area in question.

Designing a strategy

One aspect an effective strategy considers is risk avoidance. For example, you might simply decide not to have anything to do with a job where ACRM is present. However, though risk avoidance is effective, it requires you to be aware of the risk in the first place to subsequently decide to avoid it.

Another primary component of a risk management strategy is to use risk- or loss-control efforts to reduce loss frequency and severity. This can be done through training, audits and other evaluative efforts.

When you are designing your risk management strategy, you also should consider risk financing techniques. The use of insurance deductibles is a great way to regulate your risk.

Captives and risk-retention groups also are attractive options—however, they have certain thresholds that must be met to qualify, as well as big downsides if you are not actively managing your risks with loss-prevention programs.

Risk transfer is another financing technique—one not new to roofing contractors. One method is to transfer your risk to an insurer through an insurance policy. However, do not assume the insurance company will pay all claims. Insurance policies are carefully crafted, and even what seems to be the most obvious of loss coverage could be denied. And if it is denied, you will be left to pay the loss yourself or sue the insurer.

The other risk-transfer mechanism occurs through effective hold-harmless and indemnification clauses. Find an attorney who is well-versed in construction—preferably roofing—and have the attorney teach you what to look for in your contracts.


Step four in the risk management process, implementation, is relatively easy if you have completed the three previous steps. This is where communication, training and policy establishment become critical to making sure your decisions are realized in the workplace.


Review everything you've decided and consider how well it has been implemented—this is an often overlooked but critical step. A review can help you determine whether you need to make changes to your policies and procedures, change your insurance coverage to better protect your assets or revise contract language as a result of an unexpected loss you experienced.

A loss can happen with even the most sophisticated risk management programs, but the important thing to remember is if it does happen, you're in much better shape to absorb and manage the loss and lessen its effects on your business.

OSHA proposes a safety program requirement

The Occupational Safety and Health Administration (OSHA) requires roofing contractors to have written plans for specific operations related to hazard communication, lead exposures, respiratory protection and fall protection in instances where conventional fall protection is not feasible or creates a greater hazard. A comprehensive written safety program currently is not mandated by OSHA though the agency uses the existence of such a program as the basis for a good-faith reduction that can be applied in some citation proceedings.

Recently, OSHA officials have expressed the agency's intent to institute a requirement for employers to implement a comprehensive safety and health management program—an injury and illness prevention program.

At OSHA's request, an industry work group of the Advisory Committee on Construction Safety and Health (ACCSH) is providing input regarding the following six program components for the standard:

  1. Management commitment
  2. Employee participation
  3. Hazard identification
  4. Hazard control
  5. Training
  6. System evaluation

In addition, OSHA is considering the following four challenges in relation to a new standard:

  1. Establishing effective communications on multi-employer work sites
  2. Training issues considering work force turnover
  3. Mobile and temporary workplace issues
  4. Requiring proper paperwork/documentation

Importantly, at the recent ACCSH meeting, it was announced the standard draft had been sent for the required Small Business Regulatory Fairness Act (SBREFA) review. The fact that OSHA is at the SBREFA review stage so quickly is telling. The proposed OSHA rule is expected to be published soon, and OSHA will request comments on its provisions before publishing a final regulation.


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