Let's say you own a landscaping business, you're familiar with green roof technology, and you're thinking of taking it and your employees – literally – to the roof. Have you also thought about a key safety issue facing your employees when they've reached the top?
For the uninitiated, green or eco-roofs – more properly known as vegetated roofs – are thin layers of living vegetation installed on top of conventional flat or sloping roofs. Many of these roofs are installed or maintained by businesses that specialize in green roofs, but traditional landscaping businesses have gotten involved, too.
Most landscapers probably know that Oregon Landscape Contractors Board regulates landscaping work in Oregon. Their jurisdiction includes licensing for installing landscaping on "roofs, walls, and structures and overseeing the installation of green construction elements such as plants and growing media, filters, drainage, aeration mats, and root barriers; the addition of nursery stock and elements to support that which is above the roofing membrane." The licensing exam also includes questions about worker safety, covering equipment, first aid, hazardous substances, and Oregon OSHA.
If your employees are going to be working on rooftops – installing an entire green roof or simply maintaining existing landscaping – you'll need to think about when and how to protect them from falling.
They'll likely need some form of fall protection if they're working on a roof that's 10 or more feet above the next lower level and has unprotected edges. Generally, "unprotected" means a roof edge without guardrails or parapets at least 39 inches high. Your employees also need to be protected from falling into exposed holes and skylights that are six feet or more above lower levels.
The safety requirements for your employees, including fall protection, may be specified by the general contractor if you're installing a green roof as part of a larger construction project. But don't assume that will happen. For example, the contractor might require roofers to set up guardrails around the roof perimeter while they install the roof membrane, but those same roofers might take the guardrails down when their work is done, leaving your employees exposed to falls when they install landscaping. And if there's no general contractor involved, you're on your own. The bottom line: know how to protect your employees when they're working on the roof.
It doesn't matter whether your employees are installing a green roof – i.e., installing the landscaping above the membrane – or maintaining landscaping that's already there; they'll need fall protection if they're exposed to falls. If the roof perimeter lacks guardrails or parapets at least 39 inches high, they'll probably need protection. What are the options?
You'll find Oregon OSHA's fall protection requirements for general industry work (which includes landscaping) in Subdivision 2/I, Personal Protection Equipment [437-002-0134(5)].
You can't assume your employees know how to protect themselves from falls, especially if they're working on a roof and using equipment such as personal fall arrest gear for the first time. They'll need to be trained about the hazards at the site so that they recognize them and know how to protect themselves.
As the employer, you can determine how to train your employees; however, the person who does the training must be a competent person – i.e., someone who can identify hazards at the site, who has management authority to control them, and who knows how to use and operate any fall-protection gear that your employees may need.