All Skylights Require Fall Protection

The OSHA letter of interpretation regarding Skylights confirms that fall protection is required.

“29 CFR 1910.21(a)(1) … defines floor opening as: ‘An opening measuring 12 inches or more in its least dimension, in any floor, platform, pavement, or yard through which persons may fall, such as a hatchway, stair or ladder opening, pit, or large manhole.’

A definition given in Webster’s New Collegiate Dictionary (1977 edition) for ‘hatch’ is ‘an opening in the … floor or roof of a building’; the same entry gives ‘hatchway’ as a synonym.

Using these definitions, therefore, OSHA concludes that a skylight should be regarded as a hatchway, i.e., an opening in the roof of a building through which persons may fall. 29 CFR 1910.23(a)(4), therefore, requires that skylights in the roof of buildings through which persons may fall while walking or working shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.

When a skylight screen is selected for safeguarding the opening, and in the event the skylight is constructed of plastic material subject to fracture (as glass would be), then the skylight must at a minimum be provided with a skylight screen capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen.

On the other hand, a plastic skylight which can provide the necessary structural integrity to support the 200-pound load would not be required to be further safeguarded, since it would meet the intended function of a screen as well.

As expressed in 29 CFR 1910.23(e)(8), the primary function of the screen is to support at least a 200-pound load such as a person may place upon it. This provision further relates that the screen shall provide a minimum deflection so as not to break the glass; but that portion of the requirement may be inapplicable when no glass is present. (The concern for breaking the glass results from the possible fragment exposure to persons beneath the skylight.)”

Look for more OSHA letter of interpretation at:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19180

About CSG Safety Services Group, LLC: CSG Safety Services Group, LLC designs and installs window washing systems nationwide. CSG provides inspections, testing and certifications for all window cleaning equipment. CSG provides consulting up to full design/build services. The CSG Safety Services Group promotes window washing system solutions with safety, usability, and cost effectiveness in mind. www.windowwashingsystems.com.

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