An HVAC technician uses a portable ladder to access a low slope roof 12 feet high. The ladder is secured to the building and is placed at a 4/1 angle. The side rails of the ladder extend three feet above the roof landing. The HVAC unit to be worked on is 25 feet from the edge of the roof.
Question: When the employee steps onto the roof’s landing from the portable ladder, and while the employee is walking to the HVAC unit, is the employee required to have fall protection?
Response: No. OSHA does not have specific standards that require fall protection when an employee steps off a portable ladder on to a low slope roof and walks directly from the ladder to the work area 25 feet from the edge of the roof. However, when the employee performs work 15 feet or more from the roof’s edge, the employer, depending on whether the work is both infrequent and temporary, may be required to provide fall protection in accordance with 29 CFR 1910.28(b)(13)(iii)1.
Question: Does the employee need to have guardrails on the landing surface of the low slope roof once the employee steps off the ladder on to the roof?
Response: No. OSHA does not have specific standards that require guardrails on the landing surface on each side of the portable ladder when an employee steps on to a low slope roof. However, in accordance with 29 CFR 1910.28(b)(13)(i) “[w]hen work is performed less than 6 feet (1.6 m) from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system.”
1 See https://www.osha.gov/laws-regs/standardinterpretations/2020-06-12
Source: https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1