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Guards/fall protection IMC 304.11

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klarenbeek

Silver Member
Joined
Jan 28, 2010
Messages
421
Location
Sioux Falls, SD
Has anyone else questioned the exception to IMC 304.11 for the requirement of guard rails where mechanical equipment or roof hatches are within 10' of a roof edge?

"Exception: Guards are not required where fall arrest/restraint anchorage connector devices that comply with ANSI/ASSP Z359.1 are installed."

If you read the commentary on it, it makes no sense that the exception is even there:

"Restraint systems have limited application for flat roofs, where mechanical appliances and equipment are typically located, because of the impracticality of workers navigating around rooftop heating, ventilation, and air conditioning units while tethered to anchorage points."

Based on past experience in the industry, I fully agree with what the commentary says. The problem is that's the exact location the exception is allowing their use in place of a guardrail. "Here's an exception you can use even though its not practical to use..." I've been successful getting it amended out locally, but have been informed it will no longer get amended out going forward. It's not the HVAC contractor that chooses which system to use, but the architect, who will never have to actually rely on it. There's also NO direction as to placement of the anchorage points. Even the OSHA standard is no help there.

Thoughts?
 
I think the location of the hard point has to comply with the fall arrest requirements, that does not allow the tie point to become a pendulum for the trades person, maybe it is better said as the person can not fall more then 6 feet
 
TheCommish said:
I think the location of the hard point has to comply with the fall arrest requirements, that does not allow the tie point to become a pendulum for the trades person, maybe it is better said as the person can not fall more then 6 feet
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So where would that be? OSHA gives very little direction with placement, other that along the roof ridge. There is no ridge on a flat roof. How far from the edge, how far from the serviceable item, etc. Some anchors "recommend" between 6 and 10 feet from the edge is the best I've seen, and recommendations aren't enforceable.

My bigger beef with the exception is it allows something that the commentary then turns around and says isn't practical and the commentary also actually says the exception is aimed at sloped roofs not flat roofs, even though flat roofs are the vast majority of where this section is applied. Equipment on sloped roofs would require a platform with rails.
 
I don't enforce OSHA, my sense if y the employee gets hurt, the employer did not put the hard point in the correct spot or failed to train the employee in correct procedures
 
I don't enforce OSHA either, but the IMC gives ZERO direction on placement of anchorage points that the IMC allows as an exception to code required guard rails. This is permanently placed anchorage points installed in new construction. The employer of the service tech working on the unit five years later had nothing to do with placing the anchor point. As an inspector, how do I enforce this exception???
 
That anchor point will never be used, so don't worry about placement. At least, that's how the trade guys work around here...

If you have a guy responsible enough to tie off, they will figure out a way to tie off whether an anchor point is provided or not.

I would like to remove that exception too, completely defeats the purpose of that section. My guess is that is why that exception was proposed, to completely gut the requirement.
 
Beniah Naylor said:
That anchor point will never be used, so don't worry about placement. At least, that's how the trade guys work around here...
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Same here. And the commentary is right. With what an HVAC service tech does the harnesses are impractical and make their job MUCH more difficult. And as an inspector I'd at least like to get the anchors in the right locations for them.
 
So what determines if the anchors are placed properly in relation to the unit or roof edge? Since they are about 4 1/2' from the roof edge, do you need another farther away to get to it? Is this system too close to the edge? Old school black rubber roofs are bad enough with a layer of frost or thin ice, White membrane roofs like this can be downright scary even if you don't have to worry about sliding over the edge. HVAC service techs aren't part of a construction crew. They are usually there alone, sometimes after hours. There might be no one to find them hanging over the edge for hours.....

Does this one meet code? The anchor is about 17' away from the farthest fan. Switch this to a square package heating/cooling unit 3' from the edge with no parapet. Where do you put the anchors to service the side closest to the edge? One thing OSHA does say is the lanyard connecting the vest to the anchor can't go around sharp corners. I would put the corner of a square unit in this category. BTW, its about a 70' drop over the edge.

Fall restraint 1.jpg

Fall restraint 2.jpg

My guess is the exception was proposed by an architect that doesn't like the aesthetics of ugly guard rails. It most certainly was NOT proposed by anyone that has worked in the field in the HVAC industry.
 
Fall arrest for an HVAC system would be required if the mechanical designer foolishly put the maintenance side within 10' and didn't want to see a rail on a roof edge... no biggy. Where I've required it to be installed has been for solar installations with notification at the roof hatch of a harness and connect being required prior to exiting the hatch.
 
princeofpen said:
Fall arrest for an HVAC system would be required if the mechanical designer foolishly put the maintenance side within 10' and didn't want to see a rail on a roof edge... no biggy.
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The mechanical designer is sometimes at the mercy of the architect with unit placement. Structure needs to be able to support the unit, or in the case of the fans above it is placement of elevator and stair tower shafts in the building. Then the architect doesn't want ugly rails on their building.

So where do the permanent anchor points get placed in relation to the roof edge and unit? Most package HVAC units require maintenance on all sides, not just where the controls are. You can't have an anchor point on the side away from the edge to get to the side closest to the edge because by OSHA the lanyard can't go around sharp corners. The instructions I've seen for anchors recommend placing them 6-10 feet from the edge.
 
klarenbeek said:
The mechanical designer is sometimes at the mercy of the architect with unit placement. Structure needs to be able to support the unit, or in the case of the fans above it is placement of elevator and stair tower shafts in the building. Then the architect doesn't want ugly rails on their building.

So where do the permanent anchor points get placed in relation to the roof edge and unit? Most package HVAC units require maintenance on all sides, not just where the controls are. You can't have an anchor point on the side away from the edge to get to the side closest to the edge because by OSHA the lanyard can't go around sharp corners. The instructions I've seen for anchors recommend placing them 6-10 feet from the edge.
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I would think a lifeline leading you from roof access to appliance and then a transfer to a point near the appliance would work easily. That way you wouldn't have multiple lengths of personal line like you would on a slopped roof. Workers would only need a 2 point attached to their harness in order to do a transfer between points while remaining attached etc.
 
The cable disappears into the snow under the copper pipes in the second picture and runs under the pipes all the way past the second unit on the left, by the person in the picture. Beyond that, it re-emerges for the 4 foot stretch visible to the right of the unit in the third picture, then is lost again. Even without the snow, its located below the piping at the location where it is closest to being needed.
 
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