If you install or are considering installing rooftop solar systems, you may find yourself challenged during the
job-hazard analysis project phase to determine Occupational Safety and Health Administration (OSHA) fall-protection
rules applicable to solar roof system installations. In some cases, available fall-protection controls you rely on
may not apply to solar system installations. The nature of the installation and material used may dictate how you
protect your workers from fall hazards.
OSHA's roofing work definition will be paramount when properly analyzing which fall-protection control systems may be used to protect workers during solar system installations. Because the definition references the application of roofing materials, OSHA is likely to consider rooftop solar system installations roofing work because the material being installed comprises the weatherproofing membrane along with the solar component, or the solar components are adhered directly to the roof membrane.
But OSHA is less likely to consider rack-mounted solar arrays or panels installed on a weatherproofing membrane's surface as roofing material because they do not serve a weatherproofing function. For example, OSHA considers the installation of flashings on frames for rack-mounted solar system components, conduits or other solar element penetrations to fall under its definition roofing work.
Similar distinctions apply to repair and maintenance work related to solar components. If the work involves a roof membrane's integrity, OSHA more likely will characterize it as roofing work. OSHA is likely to view repair or maintenance to solar components in racks or panels, structural or framing elements, raceways or conduits, or junction or combiner boxes that have no effect on a roof membrane's integrity as outside the scope of the roofing work definition.
In a vast majority of instances, the practical result of this distinction will be work involving roof-integrated solar components will fall within the roofing work definition because they comprise the actual roof membrane or weatherproofing component, allowing the use of warning-line and safety-monitoring systems. Direct work on other rooftop solar components, unless performed to ensure weatherproofing of an underlying roof system, will require one of OSHA's conventional forms of fall protection (personal fall arrest, guardrail or safety net) because OSHA will not consider the solar components roofing materials.
For more information about the safe installation of rooftop solar systems, contact NRCA's Enterprise Risk Management Section at (800) 323-9545.