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No matter how secure a rooftop might be, working at height carries inherent risks. Leading edges and interior openings could be any number of stories high, rendering trip hazards and transition points more dangerous than normal. As a prime source of both fall and trip hazards, roof hatches have been the source of some confusion, particularly on the matter of roof hatch safety rails vs. roof hatch safety grab bars.
We'll discuss some of the most frequently asked questions about roof hatch safety, and how different types of roof hatch fall safety devices fit into fully compliant fall protection systems for roofs.
Yes, but not just any roof hatch safety rails will do. In past discussion, OSHA has clarified that "there is no specific requirement for grab bars." However, they also state that "there are recognized hazards associated with openings in roofs" and "the use of guardrails around the opening itself may be necessary" (emphasis added).
This was in response to questions on whether roof hatches specifically require grab bars. While OSHA fixed ladder requirements have no such requirement (see 1910.23[d][9]), they have at times invoked the merits of ANSI A1264, which states "[o]pen roof hatches should be protected."
Yes, but ANSI 1264 also "requires guardrail protection for the exposed sides of ladderway openings" on working/walking surfaces. The takeaway is that OSHA and ANSI have both stated that fixed ladder openings require guardrails, but not grab bars.
According to OSHA 1910.21(b), Scope and definitions:
"Grab bar means an individual horizontal or vertical handhold […] above the height of the ladder."
"Guardrail system means a barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface[.]"
The key difference is a matter of continuity and function. While roof hatch safety grab bars are very useful to help workers climbing out of an open hatch, they don't replace the need for continuous edge protection (i.e., guardrails) at interior openings.
In keeping with the definitions, what's needed is "a barrier […] along an unprotected or exposed […] edge[.]" Often, the safest solution is an integrated guardrail/grab bar system for hatches. The most innovative solutions achieve the best of both worlds while maintaining a clear distinction between (A) the guardrails, running continuously along exposed sides of the hatch, and (B) the grab bars, which connect the railing to the ladder.
Yes. Even if OSHA backs their determinations using ANSI standards instead of their own, they will still cite companies for unprotected roof openings pursuant to the Occupational Safety and Health Act's "general duty clause."
Be aware that any discussions OSHA has outside formal regulatory standards, like the one mentioned above, are merely advisory. They do not replace the need to reference the latest OSHA, state plan, or CCOHS standards affecting your location and industry – the only gold standard for ensuring fall safety compliance.
It's easier to understanding OSHA requirements for fixed ladder openings on rooftops by referencing the definition for "opening," found in OSHA 1910.21(b):
"[A] gap […] that is at least 30 inches (76 cm) high and at least 18 inches (46 cm) wide, through which an employee can fall to a lower level."
These dimensions apply to hatches – which, when open, also meet the definition of "unprotected sides and edges":
"[A]ny side or edge of a walking-working surface […] where there is no wall, guardrail system, or stair rail system."
We also found this term in the definition for "guardrail system," referenced above. What's needed is a guardrail barrier that protects the leading edges of the hatch, with or without grab bars.
Guardrail standards for walking-working services are outlined in 1910.29(b), which covers a wide range of OSHA leading edge fall protection scenarios. Note that OSHA 1910 applies to general industry, while the construction industry uses a slightly different definition (see 1926.751). The difference is unlikely to alter your railing requirements; but if it does, be aware that it changes the working height requirement for a leading edge from 4 ft (1.2 m), in general industry, to 6 ft (1.8 m) for any construction operation.
In either case, the dimensional and force ratings for hatch railing are the same as for any other leading edge, as outlined in 1910.29(b):
A top rail 42 in. (107 cm) above the working surface (+ or – 3 in. / 7.6 cm), measured at the top edge, and capable of withstanding 200 lb. (890 N) of downward force without deflecting lower than 39 in. (99 cm) above the surface
Either of:
A midrail halfway between the upper edge of the top rail and the working surface, and capable of withstanding 150 lb. (667 N) of downward or outward force at any point
Intermediate members, such as solid panels, meshes, or screens, along the entire opening, and with the same force requirements as midrails
An adjacent wall or parapet at least 21 in. (53 cm) high
Top and midrails at least 0.25 in. (0.6 cm) in diameter
Vertical members (like balusters) or architectural panels that leave no more than 19 in. (48 cm) of space between each member
Smooth surfaces, with no sharp edges or abrasions that could cut someone's hand or snag clothing
Non-overhanging terminal posts at the end of rails, except where they don't pose a projection hazard
Further, guardrails installed around a hole must heed the following additional requirements:
1910.29(b)(11) – Guardrails must be installed on all unprotected sides/edges of a hole.
1910.29(b)(13) – Guardrails around ladderway openings must have a self-closing gate that swings away from the hole
Generally, yes, and using the same type of swing gate guardrail enclosure for skylights as hatches is an effective way to provide easy access for skylight repairs while still eliminating exposed edges. Of course, the skylight service technician will usually require some other fall protection measure, such as a lanyard, unless there's also an OSHA-compliant screen over the skylight.
To prevent workers from losing their grip while egressing or ingressing, it's best practice to align the grab bars with the width of the ladder's side rails, and as possible. For horizontal grab bars, it's most effective to connect them near or touching the guardrails.
For maximum simplicity and economy of space, an enclosed railing/safety gate will meet roof hatch safety requirements just as well as more feature-rich options. While they don't have roof hatch safety grab bars, employees entering the hatch can still use the railing to carefully lower themselves down as they shift their grip onto the ladder.
Note that any of these solutions also prevent the trip hazards associated with roof hatches, where the top edge of the hatch and opening is usually several inches above the walking-working surface.
Even though roof hatch openings seem less dangerous than the roof's outer edge, that's not necessarily true, and the same OSHA leading edge fall protection standards apply. While it can seem enormously complex at first glance, roof hatch safety, like most rooftop safety needs, are much easier to meet with the support of a true industry leader.
BlueWater continually advances the technologies behind fall protection systems for roofs. We're proud of our role providing the most streamlined and effective solutions for the majority of fall hazards facing modern workforces today. Contact us today and one of our fall protection specialists will help to determine which roof hatch safety rails, OSHA leading edge fall protection, and overall fall protection systems for roofs will function best with your rooftop ladderway hatch.