The time to address the addition of permanent fall protection is when a building is being built or when significant upgrades to the roofing system are made. Putting fall protection in place only to remove it later does not make sense in many cases. Many buildings are topped with mechanical equipment that requires maintenance people to be on the roof regularly. Even when there is no other reason to be on the roof, what roofing contractor, manufacturer, designer, or consultant does not recommend putting people on the roof for routine, at least annual maintenance? And what kind of inspection would it be without inspecting the roof edges?

The commercial construction and roofing industry has done much to improve on worker fall protection. Safety experts will tell you that there is still much to be done, particularly in the area of worker training, to assure proper deployment of fall protection schemes. As time goes by, we expect to see more consideration in the design phase for post-construction worker fall protection.

Now let us talk about residential construction.

Residential builders typically do little to promote the use of fall protection for roofing workers on their work sites while the work is in progress, not to mention after-construction considerations. Steep-slope roofing systems built on residential construction do require maintenance from time to time including the routine inspection of vents, snow guards, solar systems, chimneys, flashings and gutters.

Roofing contractors who subcontract roofing work on new construction are directly responsible for their workers and their workers' fall protection. For the most part, the most economical and reliable solution is for them to employ personal fall arrest systems.

I believe the builder, not the roofing contractor, should be responsible for the first critical component of the PFAS: the anchorage points. Anchorage points for PFAS must be professionally designed to handle specific weight and stress loads that can be addressed only as part of the original design and construction of the roof truss and deck system. The installation of appropriately designed anchorage points should be completed under the direction of a competent person.

For the sake of the homeowner and other workers who will come later to maintain the home, the anchorage points should be constructed so as to be permanent, and be left on the home as permanent fixtures. Since installing anchorage points for use during construction is required, it would seem to make sense to leave them in place for future service.

Permanent PFAS anchorage devices are now commercially available from firms who furnish rated and tested fall protection equipment. These devices are reasonably priced, and do not distract from the aesthetics of the roof.

In the real world of residential construction, "fall protection on residential construction for roofing workers" is practically an oxymoron. The best we do typically is to install toe-boards or roof jacks. We must strive to do better.

The addition of permanent fall-arrest anchorage points for PFAS on residential construction makes sense and should be the responsibility of the builder. Any roofing contractor worth his salt would never accept an improperly constructed roof deck prior to application of the finished roof. Likewise, it should follow that roofing contractors working on new construction should formally request that appropriate anchorage points be built into the structure before sending people to work on the job, whether they be temporary or permanent.