Fall Protection on Low-Slope Roofs Covered in HVAC Units

Facility managers love low-slope roofs until they realize the mechanical contractor just unhooked a guardrail to move a unit. OSHA 1910.28 and 1926.501 treat low-slope roofs differently than steep roofs, but the danger is the same: one misstep near a skylight or parapet and a worker is airborne. The difference between a citation and a controlled job is how you design access, control zones, and rescue plans.

Map the Roof Like a Jobsite

Before anyone climbs a ladder, map the roof. Mark parapet heights, skylights (especially acrylic domes that look solid), hatch openings, and the location of every HVAC unit, exhaust fan, and antenna. Note tie-off points rated for fall arrest or restraint. Photograph the roof and store the images with the map so contractors cannot claim they did not know about hazards. Update the map whenever you add equipment or remove rails.

Decide Between Guardrails, Restraint, or Arrest

Permanent guardrails at roof edges and around skylights offer the simplest protection, but they require capital and structural evaluation. When rails are not feasible, use travel restraint systems that keep workers from reaching the edge. Reserve fall arrest systems for situations where exposure to a fall cannot be avoided, and only after confirming anchor strength, clearance distance, and rescue capability. Document the decision for each task so inspectors see that you applied the hierarchy deliberately.

Control Access With Designated Paths

Paint walking paths from roof hatches to mechanical units and install warning lines at least 6 feet from edges. Require workers to stay inside the lines unless they are tied off or the edge is guarded. For larger roofs, establish controlled access zones overseen by a competent person who can monitor exposure. That person must be able to stop work when controls fail—not just observe.

Treat Skylights Like Holes

Skylights are legally floor openings. Guard them with cages, screens, or railings. Temporary covers must support at least twice the weight of employees and equipment, be secured, and be marked "HOLE" or "COVER." Document inspections of these protections, especially after storms. OSHA cites skylight falls constantly because covers cracked or were removed during maintenance.

Plan for Rescue Before Someone Falls

If you rely on personal fall arrest systems, you need a rescue plan that does not depend on calling 911 and waiting. Train an in-house team or contract with a service that can respond quickly. Stage ladders, rescue poles, or descent devices on the roof when work occurs. Practice rescue drills so workers understand how to retrieve a suspended coworker safely.

Coordinate Contractors and Building Staff

Multiple trades often crowd the same roof. Require permits for roof access, share the hazard map, and verify their fall protection plans before issuing badges. When one contractor removes a guardrail, they must install temporary protection and notify others. Document these communications. The host employer is still responsible for controlling the worksite.

Inspect Before and After Every Job

Check anchors, rails, warning lines, and ladders before each job. Afterward, verify that controls remain in place and document any damage. Use photos tied to dates. Worksafely SMB can store these inspections and alert you when controls are missing before the next crew arrives.

Next step: Upload your roof maps into Worksafely SMB and tie them to access permits so every contractor acknowledges the hazards and required controls before climbing.