• Welcome to the new and improved Building Code Forum. We appreciate you being here and hope that you are getting the information that you need concerning all codes of the building trades. This is a free forum to the public due to the generosity of the Sawhorses, Corporate Supporters and Supporters who have upgraded their accounts. If you would like to have improved access to the forum please upgrade to Sawhorse by first logging in then clicking here: Upgrades

Fall protection @ roof

palikona

Registered User
Joined
Jan 8, 2022
Messages
61
Location
Colorado
I'm working on a project where the roof hatch and RTUs are within 10' of the parapet/roof edge. The parapet is about 24" high. The owner doesn't want to raise them or add guardrails all around to create more penetrations in the roof, so we're looking at using the exception in IBC 1015.6 Mechanical Equipment;
Exception: Guards are not required where personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed.

The structure is wood framing. I'm looking at this product: https://www.3m.com/3M/en_US/fall-protection-us/products/anchors/

Can these anchors connect to wood framing? Do I need to have a structural engineer look at this and possibly design some anchor point reinforcement at the parapet? Also, how do I even lay these anchors out? I do have a roof hatch with hatch guard. Can the railing be used as a anchor point?

I've obviously never done this before for roof protection.

Thanks for any help.
 
The 3m website has a “contact us” page where you can ask questions about the product. You might start there.
 
This is California Building Code:

1015.3 Height. Required guards shall be not less than 42 inches (1067 mm) high, measured vertically as follows: ———-

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 personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed.

1015.7 Roof access. Guards shall be provided where the roof hatch opening is 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 be constructed so as to prevent the passage of a sphere 21 inches (533 mm) in diameter.
Exception: Guards are not required where personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed.


A guard installed on top of the parapet would require a rail 18” above the parapet for a distance of 30” past each side of the equipment. That is simple to do in comparison to personal fall arrest anchorage.

The exception is a mistake. The usual HVAC service crew is one guy. That one guy would have to be equipped with an OSHA approved harness. If that one guy did fall and was left dangling he needs to be rescued sooner than later as it has been determined that prolonged dangling from a harness can be fatal.

When given a choice between a passive safety measure and an interactive safety measure it is always better to choose the passive safety measure. If dollars matter to the customer, the small amount of additional railing should defeat the 3M option.
 
Last edited:
The exception is a mistake. The usual HVAC service crew is one guy. That one guy would have to be equipped with an OSHA approved harness. If that one guy did fall and was left dangling he needs to be rescued sooner than later as it has been determined that prolonged dangling from a harness can be fatal.
100% agree, but the exception is still in the code unfortunately. As an inspector how do I enforce this section on a new building if the architect wants to use the exception? What constitutes proper placement of the anchor point? Neither the mechanical code or OSHA give any guidance.
 
100% agree, but the exception is still in the code unfortunately. As an inspector how do I enforce this section on a new building if the architect wants to use the exception? What constitutes proper placement of the anchor point? Neither the mechanical code or OSHA give any guidance.
The manufacturer, model number, location and installation instructions as well as any structural requirements shall be provided by the architect and shall be part of the approved plans.

This something the Yankee could put in his book ... and do the same for damp-proofing subterranean walls.
 
So the location is completely up to the architect? Does it need to be within 10' of the unit? 20'? Would one anchor point at the hatch 50' away meet code?
 
So the location is completely up to the architect? Does it need to be within 10' of the unit? 20'? Would one anchor point at the hatch 50' away meet code?
That is up to the architect and he must comply with the code: Exception: Guards are not required where personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed.

I do not know what ANSI/ASSE Z 359.1 requires. The architect probably doesn't either however, it falls on the architect to figure it out.
 
So I located 4 anchorage points that are spaced at about 15' apart, around the RTUs. This way, there's a lot of overlap where someone can be fixed to one of the points and access all sides of the RTUs. However, now I'm trying to figure out how one would unclip from one point when they're at another point 15' away....
 
So I located 4 anchorage points that are spaced at about 15' apart, around the RTUs. This way, there's a lot of overlap where someone can be fixed to one of the points and access all sides of the RTUs. However, now I'm trying to figure out how one would unclip from one point when they're at another point 15' away....
Cable system. The lanyard has two clips on the end for getting around anchors. Better be a red cable so when workers trip over it and fall off the roof you can at least say that they had a warning.
 
That is up to the architect and he must comply with the code: Exception: Guards are not required where personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed.

I do not know what ANSI/ASSE Z 359.1 requires. The architect probably doesn't either however, it falls on the architect to figure it out.
So I can reject it until the architect provides documentation that anchor placement meets the ANSI standard?
 
So I can reject it until the architect provides documentation that anchor placement meets the ANSI standard?
If there is a set of plans that is stamped by the architect and approved by the building department, the inspector can approve it based on the work being done according to the approved plans. I said “can approve” because the inspector can also reject it. Architects and engineers strive to get it right but that’s from an office chair. The inspector gets a view that can bring a problem to light. When that happens, it is incumbent upon the inspector to follow through. Apply your own judgement and make a decision.

By the way, I wouldn’t mention an ANSI standard unless I was familiar with the standard and had identified a discrepancy in the construction. I also would not ignore a gut feeling that something is amiss.
 
The problem I have is I have so far been successful in getting the exception removed locally but have been informed that will no longer happen. I've asked my CBO how to enforce it if the exception is used, and told that if an anchor point is on the roof, it is provided and meets the exception so code has been met. That it's basically not my problem if its not located to be used properly. I actually brought up the example of it being next to the hatch 50 feet away from the equipment and was told the same thing.
 
The problem I have is I have so far been successful in getting the exception removed locally but have been informed that will no longer happen. I've asked my CBO how to enforce it if the exception is used, and told that if an anchor point is on the roof, it is provided and meets the exception so code has been met. That it's basically not my problem if its not located to be used properly. I actually brought up the example of it being next to the hatch 50 feet away from the equipment and was told the same thing.
I have been overridden by a supervisor many times. My experience is in a jurisdiction with a few hundred inspectors…. I’ve had options that you will not have. I don’t have any further advice so I’ll say good luck with it. Tigerloose has left the building.
 
Top