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Roofing job hazard analysis (JHA) template

Roofing exposes crews to falls from edges, falls through holes and skylights, and heat and slips on the surface. OSHA requires fall protection for workers on roofs with unprotected sides and edges 6 feet or more above a lower level (29 CFR 1926.501(b)(10) and (b)(11)). Plan the protection before anyone climbs up.

The task

Tear-off or installation of roofing on a low-slope or steep roof, from roof access to final cleanup.

Steps, hazards and controls

Controls run from most effective to least. A citation beside a control means an OSHA paragraph requires it; with no citation it is good practice.

StepHazardControls
1. Plan the roof work and fall protectionNo plan for edges, holes and anchor points
  1. Eliminate: Do work from the ground or a lift where possible, such as prefabricating or staging materials off the roof.
  2. Engineering control: On steep roofs, use guardrails with toeboards, safety nets or a personal fall arrest system. (29 CFR 1926.501(b)(11))
  3. Administrative control: Write a site-specific fall protection plan and walk the roof for edges, skylights, vents and weak decking.
  4. Administrative control: Train every worker on the fall hazards and the systems in use before the first climb. (29 CFR 1926.503(a)(1))
2. Get on and off the roofFalling from the ladder or at the roof edge
  1. Engineering control: Extend the ladder rails at least 3 feet above the eave. Tie the top off as good practice. (29 CFR 1926.1053(b)(1))
  2. Engineering control: Use a scaffold stair tower or lift for steep or tall roofs.
  3. Administrative control: Keep the ladder area clear of tools and debris. (29 CFR 1926.1053(b)(9))
  4. PPE: Wear boots with soles that grip when wet or dusty.
3. Install edge protection and anchorsFall from an unprotected edge
  1. Engineering control: Erect a guardrail with a top rail 42 inches high, plus or minus 3 inches, where the plan calls for it. (29 CFR 1926.502(b)(1))
  2. Engineering control: On a low-slope roof, erect a warning line not less than 6 feet from the edge when no mechanical equipment is in use. (29 CFR 1926.502(f)(1)(i))
  3. Engineering control: Install anchors that are independent of anything holding up a platform and strong enough for the system. (29 CFR 1926.502(d)(15))
  4. PPE: Wear a full-body harness, rigged so you cannot free fall more than 6 feet or hit a lower level. (29 CFR 1926.502(d)(16)(iii))
4. Cover holes and skylightsFalling through a skylight, vent or deck opening
  1. Engineering control: Cover or guard each hole, including skylights, that is more than 6 feet above a lower level. (29 CFR 1926.501(b)(4)(i))
  2. Engineering control: Secure covers so wind, equipment and workers cannot displace them. (29 CFR 1926.502(i)(3))
  3. Engineering control: Mark covers with the word HOLE or COVER or color code them. (29 CFR 1926.502(i)(4))
  4. Administrative control: Tell the whole crew where covers are before work starts.
5. Hoist and stage materialsStruck by falling material or overloaded roof
  1. Engineering control: Use a conveyor or hoist so crew do not carry bundles up a ladder.
  2. Administrative control: Place bundles over framing, spread them out and keep them away from edges.
  3. Administrative control: Use or store mechanical equipment on the roof only in areas protected by a warning line, guardrail or personal fall arrest system. (29 CFR 1926.502(f)(4))
  4. Administrative control: Barricade the area below and use a spotter on the ground.
  5. PPE: Wear hard hats on the ground and gloves when handling.
6. Tear off and install roofingSlip, trip and nail gun or knife injuries
  1. Substitute: Use a roofing system or tool with fewer cuts and sharp edges where available.
  2. Administrative control: Sweep debris often and keep hoses and cords out of walkways.
  3. Administrative control: Keep the safety tip engaged and fingers off triggers when moving.
  4. PPE: Wear cut-resistant gloves, safety glasses and hearing protection.
Heat exhaustion on the roof surface
  1. Administrative control: Schedule hard work early, provide water and shade, and rotate the crew.
  2. PPE: Wear light, breathable clothing and sun protection.
7. Clean up and take down protectionDebris, loose fasteners and removing protection too early
  1. Administrative control: Magnet-sweep fasteners, bag debris and lower it by chute, not by tossing.
  2. Administrative control: Take down guardrails and warning lines last, only after the final walk with the competent person.

Required PPE

  • Hard hat
  • Full-body harness and lanyard where a personal fall arrest system is used (29 CFR 1926.501(b)(11))
  • Safety glasses
  • Gloves
  • Slip-resistant boots
  • Sun protection

What the standard says

  • Low-slope roofs need fall protection at 6 feet or more above a lower level. (29 CFR 1926.501(b)(10))

    “each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems,”
  • Steep roofs need guardrails with toeboards, nets or personal fall arrest. (29 CFR 1926.501(b)(11))

    “Steep roofs. Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems.”
  • Holes and skylights need protection. (29 CFR 1926.501(b)(4)(i))

    “Holes. (i) Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.”
  • Warning lines must be at least 6 feet from the roof edge when no mechanical equipment is in use. (29 CFR 1926.502(f)(1)(i))

    “When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge.”
  • Hole covers must be secured so wind, equipment or workers cannot displace them. (29 CFR 1926.502(i)(3))

    “All covers shall be secured when installed so as to prevent accidental displacement by the wind, equipment, or employees.”
  • Guardrail top rails must be 42 inches high, plus or minus 3 inches. (29 CFR 1926.502(b)(1))

    “Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) above the walking/working level.”

Training

Employers must provide a training program for each employee who might be exposed to fall hazards, and a competent person must train in the nature of fall hazards and the use of the systems in the work (29 CFR 1926.503(a)(1) and (a)(2)).

Frequently asked questions

Does OSHA require a JHA for roofing?
OSHA does not require a written JHA for roofing in the standard itself. It does require fall protection and trained workers (29 CFR 1926.501, 29 CFR 1926.503). A JHA is a practical way to plan the protection and show the crew the plan.
What goes in a roofing JHA?
List access, edge protection, hole covers, material handling, installation and cleanup. For each hazard list controls from strongest to weakest, and name the competent person and anchors.
What fall protection can a steep roof use?
Each employee on a steep roof with unprotected sides and edges 6 feet or more above lower levels must be protected by guardrails with toeboards, safety nets or a personal fall arrest system (29 CFR 1926.501(b)(11)).

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