Understanding roof access legislation

Carl Sachs* answers FAQs to help supervisors stay on the right side of the law.

Carl Sachs* answers FAQs to help supervisors stay on the right side of the law.

The need to provide a safe workplace under Australian state OHS legislation applies to roof access and it is the responsibility of the “controller of the workplace” to ensure this happens.

The states have OH&S Regulations and Codes of practice, which detail specific requirements for access and fall prevention. The legislation requires a risk assessment conducted in accordance with the hierarchy of controls, which is different for fall prevention than other areas of risk.

Fall prevention hierarchies are prescriptive and stipulate the control measures to be used.

Managing compliance with state-based legislation can be tricky when sites are spread across Australia. The national code of practice should only be regarded as guidance material but offers an excellent template for organisations trying to achieve national consistency.

2. Is there a legislative requirement to retrospectively upgrade the roof access systems of older buildings that conformed with the BCA and Building Regulations when they were built?

The overriding legislative requirement is to provide a safe workplace and to comply with current OHS legislation – irrespective of when the building was erected.

3. What are the legal requirements to update ladders if the roof access system does not comply with AS1657?

Failing to meet an Australian Standard referenced in a regulation is effectively a breach of the law and compliance with AS/NZS1657-1992 is a requirement of the NSW and Victorian regulations.

Under the Victorian regulations, a level 2 control that meets the requirements of AS/NZS1657 even brings exemptions from the ongoing requirements to assess risk, consult, train and so on.

What are the general requirements when it comes to the provision of walkways and handrails on the roof? Do walkways need to be provided to plant located on the roof?

Begin with a risk assessment and let the hierarchy of controls guide equipment selection. Guardrails eliminate high and medium-level fall hazards. Walkways matched with guardrails eliminate high-level fall hazards presented by brittle alsynite/Laserlite surfaces.

Walkways alone eliminate low/medium-level trip hazards on flat roofs and high-level fall hazards on pitched roofs. They also provide a designated path of travel to plant and equipment. They also protect the roof surface. Walkways and guardrails are both level 2 controls covered by AS/NZS1657.

5. Is wire mesh under Laserlite a form of fall protection?

Wire mesh is installed underneath Laserlite to protect roofers during the roofing process. It’s a residual of the construction process and is not for long-term fall protection.

Codes of practice lay out the method of tying off the wire mesh, wire grades and other technical data in great detail. The integrity of the mesh and its ability to control the risk is destroyed when penetrations are made in the roof (for ducting, hatches and so on).

6. What is defined as an “unprotected edge”? What is the distance that a person can safely work from an unprotected edge?

An unprotected edge is any area which presents a fall hazard of more than 2m above another level. The lineal distance from the fall hazard varies with the pitch of the roof and the legislation refers to eliminating fall hazards “in close proximity” to unprotected edges.

While 3m from the edge of a flat surface may be perceived as a low risk, the same distance on a 15° pitch would present a high risk because, if anyone fell, they would keep on rolling over the edge.

7. What height should the parapet be to ensure adequate fall protection?

A minimum of 900mm measured from the standing surface with a preference of a nominal height of 1000mm. Contractors don’t normally stand or walk in the gutter, so it should be measured from the roof surface.

8. Should roof access be restricted and, if so, to what level?

It’s a good idea to restrict access. The level of restriction depends on the type of fall prevention equipment and the tasks performed on the roof.

A high level of user skill is required for roof anchors and static lines, however much lower skill levels are required for guardrail systems, which justifies less restrictive access.

9. Is a permit system required to control roof access?

A permit system is the best way to restrict roof access. The complexity of the permit is determined by the control measures.

*Carl Sachs is a director of Workplace Access & Safety, 1300 552 984, www.workplaceaccess.com.au. Email your height safety questions to Carl at sales@workplaceaccess.com.au.