Solar Safety

or less, a safetymonitoringsystem alone may be used.A critical factor when using fall-protection systems notconsidered conventional under OSHA rules is the workbeing performed must fall within OSHA’s “roofing work”definition. OSHA defines roofing work as the “hoisting,storage, application, and removal of roofing materials andequipment, including related insulation, sheet metal, andvapor barrier work, but not including the construction ofthe roof deck.”If work being performed on a low-slope roof systemdoes not fall within the roofing work definition, onlyconventional fall protection may be used to protect workersat heights 6 feet or greater. On slopes greater than4:12, only conventional fall protection may be used toprotect workers without regard to whether the work beingperformed meets the roofing work definition.However, on some residential steep-slope buildings,other fall-protection measures may be employed under theauspices of a written fall-protection plan if you show conventionalfall protection is infeasible or creates a greaterhazard. There is a presumptionconventional fall protection is feasible and willnot create a greater hazard and, accordingly, you havethe burden of establishing the controls provided in a fallprotectionplan are appropriate.PV fall protectionOSHA’s roofing work definition will be paramount whenproperly analyzing which fall-protection control systemsmay be used to protect workers during PV system installations.Because the definition references the applicationof roofing materials, OSHA is likely to consider roofintegratedPV system installations roofing work becausethe material being installed comprises the weatherproofingmembrane along with the PV component, or the PVcomponents are adhered directly to the roof membrane.But OSHA is less likely to consider rack-mounted PVarrays or panels installed on a weatherproofing membrane’ssurface as roofing material because they do notserve a weatherproofing function. OSHA clearly considersthe installation of flashings on frames for rack-mountedPV system components, conduits or other PV elementpenetrations roofing work.OCTOBER 2013 Professional Roofing 31