A: Since the parapet wall
is only 24” high OSHA wouldn’t consider this adequate fall protection. In
order for the parapet wall to meet OSHA’s guardrail requirement of 42” (plus or
minus 3”) it would need to be 39-45” high. If you extend the height of
the parapet wall to meet OSHA’s guardrail requirements, you can operate the
cart freely on the roof. That’s assuming the parapet wall fully
encompasses the roof and your employees wouldn’t be exposed to an area where the
guardrail height wouldn’t be below 39”.
If it’s not feasible to extend
the height of the parapet wall, you are allowed to use the cart without fall
protection if you are using a warning line and the following provisions are
met:
·
1926.502(f)(1)(ii): When mechanical equipment is being used, the
warning line shall be erected not less than 6 feet (1.8 m) from the roof edge
which is parallel to the direction of mechanical equipment operation, and not
less than 10 feet (3.1 m) from the roof edge which is perpendicular to the
direction of mechanical equipment operation.
·
1926.502(f)(4): Mechanical equipment on roofs shall be used or
stored only in areas where employees are protected by a warning line system,
guardrail system, or personal fall arrest system.
·
1926.502(h)(2): Mechanical equipment shall not be used or stored
in areas where safety monitoring systems are being used to monitor employees
engaged in roofing operations on low sloped roofs.
See the OSHA standard interpretation that explains the use mechanical equipment.
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