Official Counsel to RCASF:
FRONT PAGE NEWS
19.6% workers compensation rate increase on 10/1/2016
COMMITTEE BEING FORMED- ACT NOW!
RCASF/OSHA SAFETY INITATIVE
in conjunction with Latite Roofing
RCASF is creating a Task Team Committee in coordination with OSHA and Latite Roofing. We are seeking other manufacturers and roofing contractors to participate in this industry impacting initiative.
Please review the purpose of this committee below and kindly email me your interest. We will be launching this project forthwith.
The scope of the task team is two-fold:
• Review and document “typical” current industry practices for both tile tear-off and tile loading operations on sloped roofs.
• Investigate new worker safety solutions for both tile tear-off and tile loading operations.
• Formalize our best practices and final solutions for maximizing worker safety on sloped tile roof tear-offs and tile loading operations.
There is currently an industry wide issue with tear-off operations as most steep slope (greater than 4/12) shingle and tile roofs in the local South Florida Market are being torn off without the use of conventional fall protection equipment. Most roofers are utilizing a safety monitor and some form of controlled access zone to protect their workers during this phase of operation. There is also ambiguity in the understanding and interpretation of the OSHA standards related to the definition of “residential construction”. OSHA has recently modified their interpretation of 1926.501(b)(13) and any structure that now has an interior concrete floor slab at the 2nd or 3rd level is no longer considered “residential construction”. Due to this change OSHA now enforces these structures (even residential dwellings) with tile or shingle applications under 1926.501(b)(11) which is a steep slope commercial definition. By making this change there is no longer any available “alternative methods” due to the elimination of the “greater hazard” language which was contained within 1926.501(b)(13). This means when pricing a 20-year old multi-story home or apartment building you would now need to investigate and confirm the construction method used for the interior floor construction to determine if (b)(13) or (B)(11) applies. Needless to say this creates an interesting burden on the roofing contractor when the construction methodology and hazards associated with doing our jobs have not changed at all based upon the interior floor construction. Regardless of this interpretive issue we want to develop best practices and investigate if we can collectively find a way to enhance and improve worker safety for the tear-off phase of work and also determine if we should file for some form of variance with DOL-OSHA should we determine that full tie-off or other engineering controls cannot be effectively implemented.
On the issue regarding tile loading operations, once again we are aware that a significant portion of roof tile deliveries in the Florida marketplace are distributed and placed on the roof deck without the use of any conventional fall protection equipment. We are also dealing with a somewhat new interpretation from OSHA which is two-fold. First for anyone who has chosen to vertically integrate their roofing business model to include loading services, the government has now indicated that you are no longer allowed to utilize any form of previous exemptions within the “OSHA standards” for “material loading” as defined in the standard unless you have a completely separate distribution business with a unique and separate federal ID. In addition, the previous interpretive guidance regarding material loading has been modified to state that “if adequate anchors are present they shall be used”. Previously the directive said, "should". So now if roof anchorage points are installed and available the material distributor / loading company is now effectively required to use them. As most of us know there are many ergonomic and greater hazard elements at play with roof loading especially when it comes to tile loading. In addition, there are significant liability issues at hand concerning how a distributor, who did not install the anchorages that are in place, could ever know if they are compliant. This creates a proverbial Pandora’s box. If his worker attaches and the anchorage fails, whose issue is it? In spite of some of these obvious challenges, our role here is to investigate current practices within our industry and determine if a feasible way can be developed to utilize conventional fall protection methodology or some other form of engineering control to improve and enhance worker safety while loading roof tile. Once again if the current standard is determined infeasible, we will submit a variance request to the DOL-OSHA.
Our goal at RCASF is to facilitate an industry wide clear interpretation of the OSHA standards. Additionally, we want to assure the safest/best practices in performing tile loading and tile tear-off on sloped roofs.
The deliverables of the task team will be as follows:
• Document the current typical “as-is” process analysis of tile loading and tile tear-off operations (video & SOPs)
• Generate best safety practice alternatives for tile loading and tile tear off (Based on ideas from field workers, OSHA, Roofing Contractors, and Suppliers)
• Decide and document best safety practices for tile load and tile tear-off completing video and written/visual SOPs
• Present findings to RCASF board, Condell Eastmond and other representatives of OSHA from its Atlanta Regional and Washington, D.C headquarters offices
• Request a formal variance from the B11 & B13 standards if applicable and appropriate based upon the joint findings
Please respond in the next week if you are interested in participating on this important task team by emailing admin@RCASF.org or calling 954-587-5040.
Check out our facebook page for photos from the tournament!
37th Annual Fishing Tournament
RCASF FISHING COMMITTEE 2016:
Without your commitment and tireless dedication, this event and the good it produces, would cease.
- Committee Chairman: Gene Fall; Certified Contracting Group
- Anthony Utter; GAF
- Dave Clark; JGA Beacon
- Lewis Buckner; Johns Manville
- Erica Bergeron; Gulfeagle Supply
- Pablo Acanda; Tropical Roofing Products
- Corey Daly; Daly Brothers Roofing Contractors
- Amanda Fuentes; JGA Beacon
- Lynne Johnston; Earl W. Johnston Roofing
As seen at the RCASF General Meeting, please see below for more information on the wonderful opportunities available through the ABC Institute.
Calendar of Events