Frequently Asked Questions
WHERE DOES MY ROOF REQUIRE FALL PROTECTION/PREVENTION PER OSHA CODES?
Under OSHA standard 1910.28, fall protection or fall prevention is required anywhere employees are exposed to an unprotected side or edge that is 4 feet or more above a lower level. On your roof, this typically includes:
• Roof edges and parapets that are lower than the required height.
• Roof openings such as skylights, hatches, and access doors.
• Areas near leading edges where work is being done.
• Walkways, platforms, or equipment areas within 6 feet of an unprotected edge.
In these locations, OSHA requires you to use approved fall protection systems such as guardrails, safety net systems, or personal fall arrest systems, or to implement fall prevention methods like designated walkways, warning lines, and barriers that keep workers away from the hazard.
Less that 6 feet from the edge: full fall protection is required at all times.
6-15 feet from the edge: protection is required; designated areas allowed only if the work being performed is temporary AND infrequent. Any work being performed that takes you into the 6 feet zone, full fall protection is required at all times.
15 feet from edge: No protection needed for infrequent/temporary work if employees are prohibited from nearing the 6-15 foot zone per workforce rule.
How long does a typical installation take?
Installation time varies based on the scope and complexity of the project. Six hundred to 1000 linear feet of standard Kee Guard or Kee Guard Contractor can be fully assembled by our 2-4 man crews in one 8 hour work day, once the material is on the roof
Top fixed and Kee Klamp reduce the footage amount per day due to the additional time spent attaching the footings to the room or parapet.
Crossovers and customer platforms/catwalks can take 1 to 5 days.
Do we need to protect our skylights?
Under OSHA standard 1910.28(B)(3)(i), skylights are treated as holes in the walking-working surface and must be protected to prevent falls. If employees can walk or work near a skylight and there is a risk of falling through it to a lower level, you must provide fall protection. This can include:
• A skylight screen or cover that is strong enough to support at least two times the maximum intended load. Kee Cover Skylight Screen
• A guardrail system around the skylight that meets OSHA height and strength requirements. Kee Dome Railings
• A personal fall protection system (such as a lifeline and harness) that prevents workers from reaching the skylight opening.
These protections must be in place whenever employees are exposed to the skylight hazard during normal operations, maintenance, or inspections.
Can we use chains for our ladder openings or hatch rail openings on the roof?
Under OSHA’s walking-working surfaces rules, openings at the top of fixed ladders must be protected so workers cannot accidentally step or fall through them. While chains are sometimes used, they often do not provide consistent, reliable protection because they can be left unhooked or sag over time.
A self-closing safety gate is the preferred solution because it automatically returns to the closed position after someone passes through. This creates a continuous barrier at the ladder opening without relying on workers to remember to reattach a chain. To comply with OSHA requirements, the gate should:
• Be of sufficient strength and durability to withstand expected use and impact.
• Close and latch automatically without manual assistance.
• Provide a top rail height and midrail (or equivalent) that meet guardrail criteria.
By installing a properly designed self-closing gate at ladder openings instead of a chain, you significantly reduce the risk of falls and better align your system with OSHA’s intent for secure, permanent fall protection at access points.
Are annual inspections required for fall protection systems?
Yes, OSHA and ANSI standards strongly recommend or require periodic inspections of all fall protection equipment and systems. For permanent installations like guardrails and roof anchors, an annual inspection by a ‘competent person’ ensures that environmental factors, usage, or site changes haven't compromised the integrity of the safety system. Personal fall arrest gear must be inspected before every use by the worker and at least annually by a trained professional to document its continued safety compliance.
Can a painted warning line be used on the roof instead of flagged warning line?
No, a painted line does not meet OSHA standards for a warning line system. Per OSHA 1926.502(f), warning lines must be physical barriers consisting of ropes, wires, or chains, and must be flagged with high-visibility material. A painted line provides no physical boundary or visual elevation to prevent a worker from inadvertently walking over the edge. Sun bleaching, pealing, snow, and debris can cause a painted warning line to be unseen while approaching an unprotected edge.
When do I need a vertical climbing device?
Under OSHA’s ladder safety requirements, fixed ladders that are 24 feet (7.3 m) or more above a lower level must be equipped with a personal fall arrest system or a ladder safety system. For existing fixed ladders that are 24 feet or taller and do not yet have a ladder safety or personal fall arrest system, a compliant system must be installed by November 18, 2036, or when the ladder is replaced or modified, whichever comes first.
What are the causes of the most common slips, trips, and falls on a roof?
According to OSHA, most slips, trips, and falls on roofs are caused by poor housekeeping (debris, tools, and materials left in walkways), wet or slippery surfaces, unprotected edges and openings, uneven or damaged walking surfaces, and failure to use proper fall protection or safe access routes. Employers must keep walking-working surfaces clean, dry where possible, and free of hazards, and must provide appropriate fall protection and training.
Does having bars under my skylights qualify as fall protection?
Under OSHA’s fall protection requirements, bars or screens installed under a skylight only qualify as fall protection if they are specifically designed, installed, and rated to withstand at least 200 pounds applied perpendicularly at any one area, and they fully prevent a worker from falling through the opening. If the bars do not meet these criteria or leave gaps where a person could still fall, they do not satisfy OSHA’s fall protection requirements, and additional compliant protection is required.
Although the bars may qualify under OSHA's fall protection requirements, they do not prevent debris, small hand tools, shards of broken skylight glass or plastic from falling and injuring people working or walking underneath the skylight.
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