Key Differences Between US & Canadian Roof Fall Protection Regulations

Providing roof fall protection is key for any business. If you have a business with manufacturing sites in both the United States and Canada, then you're already aware that there’s both similarities and differences in safety regulations of the two countries. When it comes to safety, there are many basics which are simply a given, such as ensuring the safety of workers and guests to the sites. However, since regulations can be tricky to navigate, keeping the differences top-of-mind is a best practice for success in order to stay compliant in each location. Today, we'll focus on a few of the differences you should be aware of.

Regulatory Authority in Canada vs. U.S. - Provincial vs. Federal

Canada and the United States have very similar rules when it comes to roof fall protection. However, these two countries implement their rules very differently. In the United States, facilities come under one central regulatory authority, OSHA or Occupational Safety and Health Administration, which defines regulations, conduct inspections, and handles safety incidents under one umbrella. In Canada, regulatory authority depends on where your facility is located and in some cases what kind of work you're performing. Most companies in Canada will fall under the authority of their local province.

Where Can You Find Safety Regulations for Your Business?

Understanding the differences between US and Canadian safety regulations can be tricky business. For example, OSHA guardrail requirements are fairly similar to Canada’s regulations, but there may be small differences depending not only on the country, but the specific region or province.

When it comes to fall protection in the US specifically, you’ll want to refer to OSHA section 1926.500, which covers all facilities in the country. Keep in mind, some individual states, like California, have their own specific safety regulations, so a cross-check with state safety regulations is a good practice.

In Canada, start with Canada's central OH&S (Occupational Health & Safety Act), which covers plants that hire federal workers. This may be applicable if you have federal contracts or do general infrastructure work. From there, check the province of your facility, which has its own guidelines. You can find those specific fall protection guides here:

• Alberta OHS covers fall protection under Part 9 of its code. These regulations cover most facilities in Alberta.
• British Columbia OHS discusses fall protection in Part 11, laying down the rules for companies in this province.
• Manitoba Workplace Safety and Health covers fall protection under Part 14.
• New Brunswick OHS covers fall protection in 91-191 with regard to rooftop guardrails and related measures in this province.
• Newfoundland and Labrador OHS gives rooftop fall protection guidelines in Part V of its code.
• The Northwest Territories have similar guidelines as part of their OHS Regulatory code, with fall protection covered in Part 9. Note that the territory of Nunavut continues to abide by these codes despite having separated from the Territories in other respects.
• Nova Scotia OHS gives relevant guidelines in Part 13, under Premises and Building Safety.
• Ontario OHS gives fall protection guidelines as part of its construction regulations in sections 26 through 29 of Regulation 213/91.
• Prince Edward Island's Worker Compensation Board administers OHS regulations that cover roof, platforms, ladders, and other fall protection guidelines.
• Quebec's Administrative Labor Tribunal administers local implementations of OHS regulations which generally follow federal guidelines related to workplace safety.
• Saskatchewan's OHS gives its fall protection and rooftop guardrail guidelines in Part IX: Safeguards, Storage, Warning Signs and Signals under paragraph 116.1 for employees subject to fall risks and also under Part VII for protective equipment and Part XVI related to Entrances and Exits.
• Yukon OHS offers fall protection guidelines as part of its general regulations for workplace safety, starting at 1.37 of the General Regulations.

Safety Rules Common to All Guidelines

While the specifics and the governing regulatory agency will depend on where your business is located, most areas agree when it comes to the minimums you need for safety. In most cases, you will need to register with the local authority and/or submit specific roof fall protection equipment such as rooftop guardrails for inspection to the local authority for you area. There are a few areas where all rules agree.

1. Fall Protection Equipment. Specific height requirements and relevant systems may vary from jurisdiction to jurisdiction. OSHA guardrail requirements agree with OHS guidelines across all of the provinces in many ways. First, you must have guardrail systems in place for any location where workers or others may fall from a substantial height. Rooftop guardrails must be tall and strong enough to protect workers from accidental falls. For example, OSHA guardrail requirements in 1910.29 give the height (42 inches or 3 and half feet) and weight requirements (at least 200 pounds of pressure.) In addition to rails or in place of them where rooftop guardrails may not be available, you may also need to provide fall systems such as body harnesses and safety nets. In Canada, the precise requirements (including inspection of equipment) will depend on your jurisdiction.
2. Controlled Access. Another key element to roof safety involves making sure that unauthorized and untrained personnel do not have access to the roof. Generally, you are required to use elements such as locked doors, hatch guards, and ladder guards to prevent anyone from gaining unauthorized access. Here again, the specific equipment will depend on the design of your factory. In any location, you may be subject to regular inspection and licensing, but specific guidelines will depend on your local regulatory authority.
3. Training Requirements. Finally, both OSHA and Canadian OHS roof fall protection guidelines require that all employees with regular rooftop access or doing any work with known fall risks must be trained in how to deal with these risks. In many cases, the local authority will provide mandatory and/or recommended classes related to fall safety. In Canada, OHS offers free online access to fall-related materials intended for use by employers and employees looking to stay up-to-date with safety regulations and overall guidelines. In the U.S. OSHA gives similar access to general tips and guidelines. Note that these general overviews won't give you everything an employer legally needs to know, but it can serve as a good starting point and general reference in order to help keep the workplace safe.

Are you looking to make your workplace safer? With some careful attention to detail and location-specific usage of the right equipment for your business, you can achieve and maintain a workplace that is fully compliant with roof fall protection laws and regulations.