Rooftop Fall Protection: Anchor Certifications, Inspections, and OSHA Requirements
Building owners and property managers alike should want to ensure the safety of all occupants and visitors who enter their premises. Unless inherently dangerous work is being performed, this is typically a simple enough task. But when it comes to performing maintenance and repairs to the building’s rooftop or exterior, safety becomes something that must be properly addressed.
When performing rooftop or exterior building maintenance, workers are at risk of falling, and there are many duties building owners and employers alike can accomplish to ensure their safety. Despite industrial awareness on the subject, falls continue to be a leading cause of injury and death in the workplace. According to the U.S. Bureau of Labor Statistics (BLS), the number of fatal falls has incrementally increased each year since 2020 and has been on an upward trend for the past 30 years.
Ideally, the future maintenance of a building and the safety of those maintenance workers would be considered during the design phase of construction. If a multi-story building is planned to have glazed walls or many windows that will require cleaning, an exterior building maintenance (EBM) system can provide workers with a safe way to perform that task. Cal/OSHA (for California only) supports this effort by requiring all new buildings over three stories to be constructed with a functional EBM system for future building maintenance.
In states where an EBM system is not mandated, architects and building developers should embrace their responsibility to future workers who will maintain the building throughout its life cycle. Providing future workers with engineered means to safely clean and maintain the property will add to the building’s integrity, longevity, and (likely) property value.
Additionally, incorporating EBM and other rooftop fall protection equipment into the initial design of a building will significantly reduce the cost of ownership of the equipment. Regardless of whether fall protection equipment is installed at initial construction or retrofitted to existing structures, it will be subject to annual inspection, certification, and recertification, and require maintenance over the years. This article will discuss the difference between non-certified and certified anchors, as well as other aspects involved in maintaining a robust rooftop fall protection plan.
Non-certified Anchors
There are two primary types of fall protection anchors: non-certified and certified anchors. The term “non-certified” is a slight misnomer, as all fall protection anchors must be certified by their manufacturer to comply with minimum OSHA requirements and the ANSI Z359.18 standard. However, in this case, the clarification is that the end user is not self-certifying the anchor to perform any duties other than its original manufactured intent. With all non-certified anchors, use and installation may not deviate from what is written in the product’s manual. Additionally, it is important to ensure the mounting substrate is compatible with the purchased anchor or is rated to withstand at least 5,000 pounds.
Non-certified anchors are extremely common. If one purchases an OSHA-compliant, ANSI-certified anchor from a safety supplier, they are purchasing a non-certified anchor. It will have specific uses, limitations, and mounting instructions included from the manufacturer. Users may not deviate from the manufacturer’s instructions. In fact, failing to follow manufacturer instructions is a citable offense from OSHA.
Certified Anchors
The unqualified eye might not be able to detect the difference between a certified and non-certified anchor. In many cases, the same anchor can be used as either type. It is not necessarily the construction of the product that “certifies” the anchorage, but the process in which it is approved for fall protection use and the task being performed with the anchorage. Certified anchors are required for several scenarios. Let’s discuss a few:
Mounting Structure Cannot Withstand 5,000-Pound Load Requirement
Employers must “certify” anchors before use when the substrate structure is not rated to withstand a 5,000-pound load. This is common for normal fall protection operations, but when limited anchorage mounting options exist. If this is the case, a Qualified Person (in other words, a professional engineer) must determine the ultimate load rating of the anchorage location. If the Qualified Person determines that the substrate is rated to a minimum of twice the maximum arresting force anticipated, they can “certify” the anchor.
Engineered Fall Protection Systems
Another scenario that requires certified anchors is when an engineered fall protection system is specified for a rooftop. A permanent horizontal lifeline (HLL) system is a great example. Since these fall protection systems are typically custom-designed for each application, engineers must be involved in the design, installation, and documentation of the system components.
The system’s documents provide important details, such as the maximum number of users allowed, supporting structure requirements, equipment load ratings, lanyard compatibility, fall clearance requirements, and force levels anticipated on the system during a fall event.
Exterior Building Maintenance Systems
EBM systems will also require certified anchors to ensure worker safety. One example of an EBM system is a rope-descent system, where workers will connect fall protection equipment to a certified anchor and descend down the side of the building to perform window washing or other facade maintenance activities. Other EBM systems may require davit arms or outriggers to connect rope-descent systems over weak parapets or to attach swing stages for multiple workers.
Both systems and others that are similar will require the anchors being used to first be certified by a Qualified Person. For these rope-descent systems, the anchor will be initially load-tested to withstand a static load of 1,250 pounds and must pass a 2,500-pound pull test as well. The Qualified Person must finally certify the anchorage to withstand an ultimate load of 5,000 pounds.
Furthermore, EBM systems must be robust enough to cover workers wherever they must work on the building. ANSI guidelines require workers to stay within 15 degrees of their anchor, so multiple anchors might be required to ensure the entire building can be serviced and workers can always safely access their appropriate anchorage.
Anchor Re-Certification
Once an anchor is certified for fall protection use, employers must ensure they keep the certification valid. For active fall protection systems, anchors must be re-certified by a Qualified Person every five years. For rope-descent systems, anchors must be re-certified every 10 years. Ideally, the firm that installed the system will stay vigilant and notify the owner of when re-certification is due, but employers are responsible for staying on top of their anchor certifications. If a system does not have a valid in-date certification, a recertification needs to be performed prior to use.
The re-certification process includes a visual inspection for defects or abnormal wear, load-testing to ensure the anchor’s integrity and further analysis to ensure the system complies with current regulations and standards. Anchor certifications and re-certification documents should be retained by the building owner to ensure they remain compliant with inspection and certification timelines. Some companies, such as Diversified Fall Protection, will make these required documents readily available should they ever be needed.
Anchor Inspection Requirements
All fall protection equipment is required to be visually inspected prior to each use. This inspection should be performed by the worker authorized by their employer to use the equipment and applies to all components of their fall protection system: their harness, connection device (lanyard or SRL), and anchorage. Once the equipment passes its pre-use inspection, it is okay to begin use.
Additionally, all fall protection equipment must be officially inspected by the organization’s Competent Person at least once per year. The employer must document this annual inspection and retain the record for the equipment's lifetime in case a fall incident ever occurs, and inspection logs must be reviewed as part of the investigation. Fall protection companies or any other ANSI-certified inspector can also perform these inspections for the employer.
Maintaining a Successful Rooftop Fall Protection Program
Once anchors are installed, certified, and inspected, they are ready for use. Employers should provide relevant training to all authorized users as frequently as needed. OSHA mandates that fall protection training be performed when changes occur in the workplace (e.g., new equipment installation, equipment upgrades, etc.) or whenever an employee displays a gap in understanding of basic fall protection principles. Training must be given to the employee in a language and format that they understand, so this might include bilingual training programs when relevant.
Installing and providing fall protection equipment is one thing. Ensuring employees comply with corporate policies, OSHA regulations, and ANSI guidelines is another. When choosing a fall protection partner to provide solutions to your facility, it is important to consider not just the immediate services needed, but services that will be required in years to come. Annual equipment inspections, anchor re-certification, and employee training are just a few examples, and it will be more efficient to work with an industry integrator who can provide comprehensive fall protection needs.
When we prioritize worker safety and provide proactive fall protection equipment, we elevate our collective safety culture. Every organization has an opportunity to improve its current fall protection programs and ensure that every worker, contractor, or inspector who visits its rooftop is protected from falling. Together, we can build a safer world where everyone has the chance (and is provided with the resources) to go home safely at the end of the day.
