Unprotected skylights can be dangerous and lead to deaths. A worker may trip, lean, or back into a skylight and fall to the ground below. For this reason alone, protection from these hazards is of primary concern. Cal/OSHA treats a skylight the same as a hole in the roof or the leading edge of a roof. The following provides a summary of skylight safety requirements and methods of fall protection.
The first question that arises is, “When does a skylight need to be guarded?” The short answer is, whenever someone is within 6 feet of the skylight, unless the areas with skylights are in inaccessible, or administrative controls are in place to avoid those specific areas. It is the responsibility of the building owner to ensure this occurs.
According to 8 CCR §3212, Cal/OSHA requires that when workers approach within 6 feet of any skylight they must be protected from falling by one of the following:
- Skylight screens installed above the skylight. The screens must be designed by a qualified person. The screens must be able to receive the load without deflecting downward sufficiently to break the glass below them.
- Skylight screens (such as “burglar bars”) installed below the skylight. An inherent safety consideration with these types of screens is that the falling worker will break the glass while falling. A screen may not be used for fall protection if the broken skylight glazing will pose an impalement hazard to the worker who has fallen through the skylight and is lying on top of screen. Assuming an impalement hazard does not exist:
- Screens installed at the same level or higher than the walking/working surface must be able to support 400 pounds. (see design, construction and installation requirements below).
- Screens installed within 2 feet of the walking/working surface must have the same strength requirements as listed below with an increased strength based on the fall distance below the walking/working surface to the skylight as determined by a qualified person. A screen more than 2 feet below the walking/working surface may not be used as fall protection.
Design, construction and installation of the screen or cover must meet the support requirement of 400 pounds or twice the weight of workers, equipment and materials that may be imposed on any one square foot of the screen at any time. Grillwork openings in the screens must not be more than 4 inches by 4 inches or of slat work of not more than 2 inches wide or other material of equal strength and similar configuration.
Qualified person means one who, by possession of a recognized degree, certificate, professional standing, or who by extensive knowledge, training and experience has successfully demonstrated an ability to solve or resolve problems relating to the subject matter, the work, or the project. The determination of whether an employee is a qualified person is made by the employer.
Other acceptable guarding methods are as follows:
- Standard guardrails that meet the requirements of Section 3209. Portable guardrails may also be used.
- Personal fall protection the meets the requirements of Section 1670. Portable anchor points are available.
- Covers over the skylights themselves meeting the strength requirements as listed above. The employer must receive documentation from manufacturer of the cover prior to the start of work that it will meet the strength requirements.
- Skylight nets must be of natural or synthetic fiber to absorb a 400-pound load dropped from 42 inches above the surface of the net. The maximum size of the mesh must not exceed 36 square inches or be longer than 6 inches on any side. The crossing must be anchored to eliminate frictional wear. The net itself can be no larger than 12 feet by 12 feet. The nets must be inspected daily by an authorized person before they are relied upon for fall protection. The net cannot be damaged or modified from the original manufacturer’s design. The net must have a manufacturer supplied expiration date. If there is no expiration date it may not be used. Care, maintenance and storage of nets must be in accordance with the net manufacturer’s recommendations. Nets must be removed from service under any of the following conditions:
- Frame becomes warped, bent or distorted. o Netting becomes torn, unraveled, cut or has excessive slippage of the net crossings.
- The net has been modified from the manufacturer’s design or specification.
- Recommended service life of the net (according to the manufacturer) has expired.
Where nets are used, workers must be trained on recognizing hazards of falling into nets and on the procedures to be followed in order to limit the potential injury from falls including the tested limits of the net, factors affecting net life (i.e., sunlight, abrasion, etc.) inspection requirements and records, manufacturer instructions on the use and limitations of the skylight net and procedures for retrieving a worker who has fallen into the net.
Note: Exceptions to other guarding methods include when the work is of short duration and limited exposure such as measuring, roof inspection, electrical/mechanical equipment inspection, etc. and the time involved in rigging and installing the safety devices as listed provided that adequate risk control is recognized and maintained.
Bottom Line: Most skylights are not designed to be structural, meaning the manufacturer is not anticipating a person’s body weight striking or leaning on the skylight. Skylights are designed to let in natural light without letting in water and debris from the outside. Consider a skylight as a hole in the roof and ensure it is properly guarded from falls.
Note: This information was provided by Tim Bormann, CIH, FAIHA, The Cohen Group