Thursday, January 3, 2008


After my last blog on honesty, I feel a need to get back to safety, so here you go you safety nuts.

Analyzing The Safety Needs Of A Roofing Project.

The Roof can obviously be a dangerous place to work. As the Safety Manager for two large commercial roofing and sheet metal contractors, it is my job to help the company make inherently dangerous work safer. This requires understanding the hazards and risks involved in the industry and, eliminating them, or at the least, reducing both to acceptable levels by designing safe or safer procedures of operation—System Safety. A hazard is a condition or situation that has the potential of evolving into an accident, or as Roland and Moriarty describe it, “when activated, transforms the hazard into a series of events that culminate in a loss (an accident).”[1] Risk, the evaluation of potential loss, “is related to the “probability of a mishap in terms of hazard severity and hazard probability.”[2]
Site Specific Safety Plan

As the safety manager, it is my job to research OSHA standards, and to see that the company is compliant. But perhaps more importantly, as the designer of a safer system, it is my responsibility to, perhaps, analyze industry data and create a system designed to meet our company’s specific safety needs. Each job we do has different challenges, and plans are needed to meet those specific challenges. The “Site-Specific Safety Plan” is that tool that I use to systematize safety for our company.

The Site Specific Safety Plan is based on analysis of industry data, the particular characteristics of the specific work site, and the company’s safety resources. The bottom line is the need for the company’s work to be profitable. The site-specific safety plan must keep OSHA happy to avoid potentially costly fines—a costly fine for noncompliance with OSHA standards could easily remove the profit from any job. Accidents on the job are even more potentially costly—property damage, injuries and deaths are not only costly in monetary measurement, but destroyed lives and pain and suffering are difficult if not impossible to measure.

OSHA Standards
OSHA’s goal is, “to assure so far as possible every working man or woman in the nation safe and healthful working conditions and to preserve our our human resources.’[3] The standards related to the roofing industry are found in OSHA Construction--29 CFR 1926. These OSHA standards are designed to eliminate or reduce hazards in the construction industry and lessen the likelihood of accidents in the workplace.
Roofing Hazards

I have to admit that when I became a safety manager in the roofing industry eight years ago, I entered with some misconceptions. Like I suspect most people would have thought, I thought the majority of my time would be spent making sure that the workers were complying with OSHA’s fall protection standards.[4] But, I soon discovered that fall hazards only represented the tip of the proverbial iceberg with respect to roofing industry hazards. Dangers on a roofing crew might include cuts, punctures, broken bones, severed limbs, chemical poisoning, respiratory damage, auditory damage, and physical reactions to extreme temperatures (hypothermia, dehydration, heat exhaustion and heat stroke). Many of these hazards could result in fatalities, if care is not given nor attention paid to eliminate or mitigate them. All potential hazards should be analyzed and addressed in the site-specific safety plan.
It is understandable that fall hazards “get the press.” Statistics clearly show that the most serious accidents in the roofing industry result from falls. Roofing work, of course, is performed 99.99 % of the time—this is admittedly my best guess—from heights of fatal proportions under the right circumstances. According to recent NSC research, the construction industry’s occupational injury death rate consistently ranks the third highest among all major industries in the United States. These rates range from 13.3 deaths to 14.4 deaths per 100,000 workers since 1992. Among all risk exposures in the construction industry, falls to lower levels were the most significant cause of fatalities. They accounted for 372 (nearly 32 percent) of the 1,171 fatal injuries in 1998. Within this category of exposures, 123 accidents (33 percent) were categorized as falls from roofs. These include falls through existing roof openings, roof surfaces and skylights or from roof edges.[5] These statistics suggest that fall protection should have a high priority in the site-specific safety plan.

Be that as it may, when one looks at injuries apart from fatalities, the other roofing hazards begin to loom larger on the safety horizon. The chances that a roofer will suffer injuries other than those caused by a fall are much greater. During a period of three years (2000-2003), while I was the safety manager for a roofing company in the Midwest—I became a safety consultant in 2002, but kept the company as a client—we had experienced no injuries due to falls. In fact, my research of their injury reports of the prior 30 years showed a vast assortment of injuries (cuts, punctures, burns, and breaks) but only one incident of an injury due to a fall, and it was serious enough to end the employee’s roofing career. Nonetheless, it should be recognized that the potential is always there for a terrible tragedy and the potential loss from a fall should not to be taken lightly.

My research of the those 3 years (2000—2003) of injury reports for the company revealed the following statistics: 4 back and neck injuries, 12 sprained limbs, 8 cuts or punctures that needed emergency response, 2 eye injuries which required medical attention, 7 burns (with some 3rd degree damage), 2 heat related injuries (heat exhaustion), and broken bones. Their last injury in 2003 was a burn to a workers face (50% of his head). Only the quick response of his fellow workers—they immediately cooled the asphalt on his face with cold drinking water—kept the hot asphalt from burning deep into the skin causing 3rd degree damage.

This suggests to me that systems for material and equipment handling need to be made safer. Due to the great likelihood of these types of injuries and their cumulative effect in terms of loss to individuals and the company, site-specific safety plans must also focus heavily on seemingly less important operations such as housekeeping and tool and equipment use and upkeep.
Asphalt Fumes

For a time, there was concern in the roofing industry for exposure to asphalt fumes. Fumes from adhesives, primers and cleaners for one-ply rubber systems are not very hazardous due to the open-air application that is normal and are not as oppressive to the olfactory senses as asphalt seems to be. Asphalt has trace amounts of a number of compounds—polynuclear aromatic hydrocarbons (PAHs) that have produced tumors when applied in high concentrations in "skin-painting" studies involving laboratory animals. But, no convincing evidence has been developed indicating these compounds routinely are present at significant levels in the fumes that are created when asphalt is heated during the roofing process or that exposure levels pose a cancer risk to roofing workers. However, in an historical context, the possibility of a cancer risk is sufficient to draw intense interest by government health officials.

Since 1990, scientific groups have reviewed the scientific evidence to decide whether to regulate or classify asphalt fumes as a cancer-causing substance. None of these groups, including OSHA, Cal/EPA NIOSH, and IARC, found adequate evidence justifying the classification of asphalt fumes as a cancer-causing substance. The latest comprehensive scientific review that I read, completed by a science advisory committee evaluating the adequacy of the current occupational standard for asphalt fumes in California, decided without dissent after examining the latest data, that no new regulatory action was needed.

Though there have been proposals as late as the 1990s, OSHA has no current standard for a permissible exposure limit for asphalt fumes. NIOSH recommended that asphalt fumes be considered a potential occupational carcinogen in 1988. A NIOSH report in 2003 stated:
In a 1977 criteria document [NIOSH 1977], NIOSH established a recommended exposure limit (REL) of 5.0 mg/m3 as a 15-min ceiling limit for asphalt fumes measured as total particulates. The NIOSH REL was intended to protect workers against acute effects of exposure to asphalt fumes, including irritation of the serous membranes of the conjunctiva and the mucous membranes of the respiratory tract. In 1988, NIOSH (in testimony to the Department of Labor) recommended that asphalt fumes be considered a potential occupational carcinogen [NIOSH 1988]. In a later document [NIOSH 2000], NIOSH published a review of the health effects data available since the publication of the 1977 criteria document [NIOSH 1977].[6] The current American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV) for asphalt fume is 0.5 mg/m3 (benzene-soluble aerosol of the inhalable fraction) as an 8-hr TWA concentration with an A4 designation, indicating that it is not classifiable as a human carcinogen [ACGIH 2002].[7] The extent of worker dermal and airborne exposure to asphalt fumes during the asphalt roofing process is limited. Typically, asphalt fume exposures are determined from personal-breathing-zone (PBZ) samples collected at different worksites and such findings vary greatly due to the different work conditions (wind and temperatures) and varying work practices. They did determine, however, that increased kettle temperatures from 500 degrees F, “caused a dramatic twofold increase in measurements of total suspended particulates.”[8]

On a positive note, data gathered by Owens Corning seemed to show a trend towards overall improvement in the industry. Asphalt fume exposures have decreased tenfold with median exposures dropping from 0.6 mg/m³ to 0.06 mg/m³ from the earliest period (1977-82) through the most recent period (1995-99).[9] These improvements are largely due to process improvements and equipment to reduce exposures. The measured asphalt fumes exposure levels in Owens Corning's plants overlap the range of exposures observed in actual roofing procedures and is judged to be similar.

Other conditions were contributing factors in the study. The study found that age and cigarette smoking were the strongest predictors of lung cancer and NMRD mortality in workers:
A history of cigarette smoking increased a worker's risk of dying from lung cancer 10 times and increased a worker's risk of dying from NMRD nearly seven times.” Mortality from lung cancer and NMRD was unrelated to occupational exposures to asphalt fumes—no continuously increasing dose-response relationships between cumulative asphalt fume exposure and mortality risks were observed. [10]

It always seems ironic to me to hear a worker complain about the asphalt fumes and worrying about possible carcinogens with a cigarette dangling from his lips. Signs and symptoms of NMRD morbidity were not related to occupational exposures to asphalt fumes. Employee demographics best explained respiratory symptoms, such as an unusual cough, wheezing or shortness of breath and respiratory signs such as impaired pulmonary function or abnormal chest X-ray.
Fumes from adhesives, primers and cleaners for one-ply rubber systems are not very hazardous due to the open air application that is normally used.

Silicosis, one of civilization’s oldest known occupational diseases, is the other major concern for the roofing industry. Hippocrates noted a link between dust and a metal digger who suffered breathing difficulties.[11] Since then, it has trouble every group of workers that are involved with dust particles. In its guide for working safely with silica, the U.S. Department of Labor says, “if its silica, its not just dust.” They estimate that more than 100,000 workers in the U.S. are at high risk in the mining industry alone. Workers in the construction industry are also at risk from crystalline silica.[12]

The tear-off process of re-roofing generates large amounts of dust particles to deal with. Dust masks are required on many tear-off jobs. Again, smoking can cause a greater hazard for those exposed to particulate matter due to the diminished ability of the smokers’ lungs to expel foreign particulates, increasing the likelihood of contracting cancer.[13]

Hot Environment of the Roof
The roof can be an extremely hot place to work during the summer months and can cause serious problems. Heat stroke, the most deadly condition related to environmental heat, occurs when the body is unable to regulate its own temperature. As the sweating mechanism fails and is unable to cool down, the body’s temperature quickly rises. With body temperatures rising above 105 degrees F in less than 15 minutes, heat stroke can cause permanent disability or even death if emergency medical treatment is not quickly given.[14] Victims need to be moved to a shady spot and efforts made to cool them with a water hose or wet towels with a fan or breeze directed on them.

Heat exhaustion, the next most serious condition related to environmental heat, is comprised of several clinical disorders having symptoms that may resemble symptoms of heat stroke in the early stages. Heat exhaustion is caused by the depletion of large amounts of fluid by sweating, sometimes with excessive loss of salt. A worker suffering from heat exhaustion still sweats but experiences extreme weakness or fatigue, giddiness, nausea, or headache. In more serious cases, the victim may vomit or lose consciousness. The skin is clammy and moist, the complexion is pale or flushed, and the body temperature is normal or only slightly elevated.[15]
In most cases, treatment involves having the victim rest in a cool place and drink plenty of liquids. Victims with mild cases of heat exhaustion usually recover quickly with this treatment. Those with severe cases may require care for several days, but there are no known permanent effects.

Transient heat fatigue refers to the temporary state of discomfort and mental or psychological strain arising from prolonged heat exposure. Workers unaccustomed to the heat are particularly susceptible and can suffer, to varying degrees, resulting in a decline in performance, coordination, alertness, and response. The severity of transient heat fatigue will be lessened by a period of gradual adjustment (heat acclimatization) to the hotter environment. This adjustment to heat, under normal circumstances, usually takes about 5 to 7 days, during which time the body will undergo a series of changes that will make continued exposure to heat more endurable.

On the first day of work in a hot environment, the body temperature, pulse rate, and general discomfort will be higher. With each succeeding daily exposure, all of these responses will gradually decrease, while the sweat rate will increase. When the body becomes acclimated to the heat, the worker will find it possible to perform work with less strain and distress. Gradual exposure to heat gives the body time to become acclimated to higher environmental temperatures. Typically, heat disorders are more likely to occur among workers who are not used to working in the heat or who have gotten accustomed to lower temperatures. The first hot weather of the summer is likely to affect the worker who is not acclimatized to heat. The worker should be given graduated workloads with enough breaks to gradually reacclimatize to the hot environment.

Hot Asphalt Burns
Burns are a constant threat in the roofing industry when working with hot asphalt and have been of special concern for me as a safety manager the last few years. Hot asphalt is typically heated to temperatures of 400-550 degrees F, depending on its type and purpose. It is commonly pumped from hot kettles into “hot luggers” or “mop carts,” or carried by hand in buckets from luggers to refill mop carts, where it is mopped onto the roof surface by workers with “hot mops” or spread by mechanical “buggies.”

In all cases, personal protective equipment (PPE), including gloves, long-sleeve shirts, long pants, leather work boots, and safety glasses or face shields (when filling the kettle or lugger) are the primary protection from burns.[16] Good “house keeping” is the next most important thing to do to prevent burns. Many burns happen as a result of a worker tripping or stumbling over materials and equipment. As stated by Leslie Kazmierowski in a Professional Roofing article, “A clean job site is not necessarily safe, but a job site littered with debris definitely is unsafe.” The National Safety Council’s data shows that one of every four lost-time injuries in the construction industry is due to bad housekeeping.[17] In every burn injury I have investigated, housekeeping was a factor.

Musculature Injuries /Cuts / Bruises
Back injuries and sprains of the extremities are common among new employees and those who have been inactive for a time. In the U.S. workforce, 450,000 people suffer back injuries every year, causing 149 million lost workdays. Education of the employee in the lifting process is essential. Proper technique must be used and effort made to get workers to work together when lifting the heavier weights.[18] Repetitive body movements and awkward positions for long periods of time also take toll on the workers back and neck. Again, ankle sprains, broken bones, lacerations and punctures are most often attributable to poor housekeeping.

In the final analysis, one must conclude that a roofer has a hazardous job. When writing a site specific safety plan, the safety manager must not only address the fall hazard inherent in his profession, but he must be also focus on the many other hazards (heat, burns, respiratory, cuts and bruises) that await the roofer as he climbs the ladder to his rooftop workplace. And he must analyze conditions and the specific job, evaluate the risks involved, and prepare the worker. Depending on the weather, the roofer may need to work in the cool of the very early mornings or late evenings to avoid extreme heat in the summer months. Depending on the type of roof system to be installed, he may have to wear special PPE. Like a Boy Scout, the safe roofer must be prepared. As a safety manager, I must help him to be prepared by knowing the hazards and developing the site-specific safety plan to provide a safer system by which he can accomplish his work.

National Center Health, Retrieved June 3, 2004,
EPA AHERA Asbestos Abatement Supervisor Training Manual (1998). META,
Lawrence, Kansas.
Greenbaum, Peter (2002). NRCA and the National Safety Council embark on a
landmark study, Professional Roofing Magazine.
Goetsch, David L. (2002). Occupational Safety and Health, Saddle River,
New Jersey, Columbus: Prentice Hall.
Fayerweather, Bill PhD, MPH and Dave Trumbore, PhD. (2002). Owens Corning
Studies Asphalt Fumes: …reveals positive news for the Industry,”
Professional Roofing, November.
Kazmierowski, Leslie (2002). Mr. Clean, Professional Roofing, February.
Martin, Joel (1999). The Basics of Back Injuries, Professional Roofing, October.
NRCA Safety Program Manual (2002), CNA Commercial Insurance, National
Roofing Contractors of America.
OSHA Standards for the Construction Industry (2002), (29 CFR Part 1926) with
amendments as of Feb. 1. 2002, CCH Editorial Staff Publication Chicago.
NIOSH Publication No. 2003-112 Retrieved May 31, 2004. Asphalt Fume
Exposure During theApplication of Hot Asphalt to Roofs,
[1] Harold E. Roland and Brian Moriarty, System Safety Engineering and Management, p. 6.
[2] Ibid., p. 8.
[3] David L. Goetsch, Occupational Safety and Health, p. 53.
[4] OSHA Standards for the Construction Industry, Subpart M—Fall Protection, 1926.500-503.
[5] Peter Greenbaum, “NRCA and the National Safety Council embark on a landmark study,” Professional Roofing Magazine, December 2002.
[6] NIOSH Publication No. 2003-112: Asphalt Fume Exposure During the Application of Hot Asphalt to Roofs
[7] Ibid.
[8] Ibid.
[9] Bill Fayerweather, PhD, MPH and Dave Trumbore, PhD., “Owens Corning Studies Asphalt Fumes: …reveals positive news for the Industry,” Professional Roofing, Nov. 2002.
[10] Ibid.
[11] Thomas Gilligan, “Is Silica the Next Asbestos? Mealey’s Litigation Report, Vol. 1, Issue 5, Jan. 2003.
[12] Ibid.
[13] EPA AHERA Asbestos Abatement Supervisor Training Manual,
[14] CDC National Center for Environmental Health,
[15] David L. Goetsch, Occupational Safety and Health, p. 247.
[16] NRCA Roofing Safety Manual. Section 21.1
[17] Leslie Kazmierowski, “Mr. Clean”, Professional Roofing February, 2002.
[18] Joel Martin, “The Basics of Back Injuries,” Professional Roofing, October, 1999.

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