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1015.6 Mechanical equipment, systems and devices.............and roof drains?

T

Tim Mailloux

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Hartford CT
The way I read this code section. roof drains with in 10 feet of the roof edge would require guards (or tie offs per the exception) as they are component that requires service (aka cleaning). What do you all think?


1015.6 Mechanical equipment, systems and devices.
Guards shall be provided where various components that require service are located within 10 feet (3048 mm) of a roof edge or open side of a walking surface and such edge or open side is located more than 30 inches (762 mm) above the floor, roof or grade below. The guard shall extend not less than 30 inches (762 mm) beyond each end of such components. The guard shall be constructed so as to prevent the passage of a sphere 21 inches (533 mm) in diameter.

Exception: Guards are not required where permanent fall arrest/restraint anchorage connector devices that comply with ANSI/ASSE Z 359.1 are affixed for use during the entire roof covering lifetime. The devices shall be reevaluated for possible replacement when the entire roof covering is replaced. The devices shall be placed not more than 10 feet (3048 mm) on center along hip and ridge lines and placed not less than 10 feet (3048 mm) from the roof edge or open side of the walking surface.
 
In my opinion, no. Roof drains are a plumbing system and not a mechanical system. This can be justified by which code regulates them: is it the IMC or the IPC?

Yes, they require maintenance on occasion, but so do perimeter flashings, copings, lightning protection, etc. If these fall into that category, then the code would require guards all the way around a building.

Mechanical equipment requires more routine maintenance than those items I mentioned above. Workers, concentrating on the maintenance of mechanical equipment, may not be aware of the danger as they move around the equipment. This does not negate the owner's obligation for compliance with OSHA fall-protection regulations when maintenance personnel is working on roof drains, but it doesn't need to be codified in the building code to provide physical protection measures such as guards.
 
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