Safe Solutions

Identifying obscure hazards

Many hazards associated with roof system removal and installation stem from using tools and equipment to perform various tasks; heights at which work takes place; using chemicals or hazardous materials; and adverse weather conditions. Additionally, there may be potentially hazardous processes taking place inside buildings where roofing work is being performed or at adjacent buildings. For example, rooftop ventilation outlets may be discharging gases, vapors and dusts that can harm roofing workers.

The Occupational Safety and Health Administration's (OSHA's) Hazard Communication standard (29 CFR 1910.1200) requires you to inform your workers about the hazardous chemicals to which they are exposed. This can be a nearly impossible task if you are unaware of the nature of manufacturing or processing operations conducted at a building on which your employees are working.

However, OSHA's Hazard Communication standard places an affirmative duty on employers operating the processes conducted inside buildings to inform other employers working at the site about precautionary measures needed to protect their employees from hazardous chemicals.

OSHA also specifies worker exposure to specific gases, vapors, fumes, dusts and mists exceeding individual concentrations set out in 29 CFR 1926.55 must be avoided. To avoid exposure, OSHA requires you to implement administrative or engineering controls in an effort to reduce air contaminants to a safer level.

Administrative and engineering controls are preferred safeguards for workers rather than personal protective equipment (PPE) because they act to eliminate hazards by, for example, shutting down equipment that produces harmful gases; rotating workers out of job tasks that involve exposures before harm can occur; or modifying equipment to minimize or eliminate hazardous exposures. PPE merely isolates or shields workers from hazards that remain ever-present. PPE failure may result in workers' exposure to a hazard's unmitigated effects.

Job hazard analyses

Hazard investigation and identification are critical when developing job hazard analyses (JHAs) for roofing projects. Rooftop ventilation issues and site-specific hazards posed by processes, operations and/or equipment on-site or at neighboring facilities often can be overlooked.

Most JHAs performed by roofing contractors appropriately focus on the tools, equipment, materials and methods needed to repair, remove or install roof systems. A significant challenge is analyzing hazards unique to the specific structure; hazardous processes, building contents or production components negatively can affect worker safety if not properly controlled.

Unfortunately, from OSHA's perspective, you carry the burden to identify the nature of gases and other exhaust from rooftop ventilation stacks or fans where your employees are working. Building or plant operations personnel ordinarily are the best sources for such information. Independent air monitoring may be required if information regarding the exhaust's nature is not readily apparent or otherwise undetermined. Once the exhaust's nature is established, proper control methods or PPE use can be instituted.

Hazards associated with operations, processes or equipment from facilities near the structure on which your employees are working are more difficult to identify and control. Dust from concrete sawing, particles from spraying operations or gases from refining processes at nearby structures or construction sites can pose dangers to your workers if sufficiently concentrated.

A useful tool

A comprehensive JHA may help you identify some of the less obvious sources of injuries to your workers. Take the time to acquire as much information as possible regarding operations at or near work sites to ensure you provide suitable controls for worker protection.

Harry Dietz is NRCA's director of risk management.



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