Mid State Roofing

Mid State Roofing, Inc.

205 Oak Drive

Lexington, SC 29073

Phone: (803) 356-1919

Fax: (803) 356-1819

COMMERCIAL - INDUSTRIAL - RESIDENTIAL
A TRADITION OF SERVICE

February 16, 1984

Mr. Joseph P. Stanton
Iovine & Woods, P.C.
Suite 200
7908 Frankford Avenue
Philadelphia, PA 19136

Dear Mr. Stanton:

This is in response to your letter of December 21, 1983, regarding skylights as regulated by the Occupational Safety and Health Administration (OSHA). This response provides an interpretation and clarification of the General Industry Standard 29 CFR 1910.23(a)(4) and (e)(8).

These regulations are included in 29 CFR 1910, Subpart D--Waling-Working Surfaces. 29 CFR 1910.21(a)(1) of the same Subpart defines floor opening as: An opening measuring 12 inches or more in its least dimension, in any floor, platform, pavement, or yard through which persons may fall, such as a hatchway, stair or ladder opening, pit, or large manhole.

Moreover, a definition given in Webster's New Collegiate Dictionary (1977 edition) for "hatch" is "an opening in the...floor or roof of a building;" the same entry gives "hatchway" as a synonym.

Using these definitions, therefore, OSHA concludes that a skylight should be regarded as a hatchway, i.e., an opening in the roof of a building through which persons may fall. 29 CFR 1910.23(a)(4) therefore requires that skylights in the roof of buildings through which persons may fall while walking or working shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.

When a skylight screen is selected for safeguarding the opening, and in the event the skylight is constructed of plastic material subject to fracture (as glass would be), then the skylight must at a minimum be provided with a skylight screen capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen. On the other hand, a plastic skylight which can provide the necessary structural integrity to support the 200-pound load would not be required to be further safeguarded, since it would meet the intended function of a screen as well.

As expressed in 29 CFR 1910.23(e)(8), the primary function of the screen is to support at least a 200-pound load such as a person may place upon it. This provision further relates that the screen shall provide a minimum deflection so as not to break the glass; but that portion of the requirement may be inapplicable when no glass is present. (The concern for breaking the glass results from the possible fragment exposure to persons beneath the skylight.)

We hope this information is helpful to you. If we may be of further assistance, please contact us.

Sincerely,

John B. Miles, Jr., Director
Directorate of Field Operations

Mid State Roofing is proud to be one of the few roofing firms to have a specialized safety compliance department. The consultants in this department are using their knowledge to help companies in this area maintain OSHA compliance in all roofing aspects as well as other roof related safety needs. From Fall-Guard brand skylight screens to fixed ladders, traffic pads and permanent mounted boarding stations, Mid State Roofing is your complete safety roofing and waterproofing provider.

What does this mean to me?

Reported Skylight Injuries

SKYLIGHT SAFETY SCREENS

One example of a widespread, particularly dangerous OSHA violation is skylight safety screens. Below are the actual regulations set by OSHA. If you have any further questions please contact your local OSHA representative.

29 CFR §1910.23 Guarding Floor and Wall Openings and Holes.
(a)(4) Every skylight floor opening and hole shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.
(e)(8) Skylight screens shall be of such construction and mounting that they are capable of withstanding a load of 200 poinds applied perpendicular at any one area of the screen. They shall also be of such construction and mounting that under ordinary loads or impact, they will not deflect downward sufficiently to break the glass below them. The construction shall be of grillwork with openings not more than 4 inches long or slatwork with openings not more than 2 inches wide with length unrestricted.
29 CFR §1926.501 Duty to have fall protection.
(a) General. (1) This section sets forth requirements for employers to provide fall protection systems. All fall protection required by this section shall conform to the criteria set forth in 1926.502 of this subpart. (a)(2) The employer shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely. Employees shall be allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity.
(b)(4) Holes. (i) Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes. (ii) Each employee on a walking/working surface shall be protected from tripping in or stepping into or through holes (including skylights) by covers. (iii) Each employee on a walking/working surface shall be protected from objects falling through holes (including skylights) by covers.
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Larry Leitner, Operations Manager | 205 Oak Drive Lexington, SC 29073 | (803) 356-1919 | LDEITNER@WINDSTREAM.NET