JHA for Roofing Work

Roofing is the trade with the highest fatal-injury rate in US construction. OSHA's enforcement focus on roofing has been continuous since the 2010 directive on residential fall protection. Any roofing JHA that doesn't take Subpart M seriously is a JHA waiting to be cited.

This page walks through what belongs in a roofing JHA — residential and commercial. Use it as a structural reference, not a finished document.

The OSHA standards that drive a roofing JHA

• 29 CFR 1926.501 — Duty to have fall protection. The 6-foot trigger.
• 29 CFR 1926.502 — Fall protection systems criteria and practices. Includes the residential leading-edge fall protection plan provision.
• 29 CFR 1926.503 — Training requirements.
• 29 CFR 1926.451 — Scaffolding (where used for access).
• 29 CFR 1926.1053 — Ladders.
• 29 CFR 1926.350–354 — Welding and cutting (hot work for roof systems).
• 29 CFR 1926.1153 — Respirable crystalline silica (if cutting tile, slate, or concrete tile).

Job steps and hazards

Residential re-roof

1. Site setup and material loading. Hazards: vehicle struck-by, manual handling. Controls: exclusion zone, mechanical lifting, hi-vis.
2. Ladder access. Hazards: ladder slip, fall during transition. Controls: 4:1 ratio, tied off, extends 3 ft above eave, two-handed climb.
3. Establish fall protection. Hazards: fall >6 ft. Controls: PFAS with engineered anchors AND/OR perimeter guardrail AND/OR safety net. If no conventional system is feasible, written fall protection plan per 1926.502(k).
4. Tear-off existing roof. Hazards: struck-by debris, slips on loose material, puncture. Controls: ground exclusion zone, magnetic sweeper, leather palms, fall protection maintained during tear-off.
5. Install underlayment / new roof system. Hazards: fall, slip on synthetic underlayment. Controls: slip-resistant footwear, fall protection through to completion.
6. Hot work (if torch-applied or hot-mop). Hazards: fire, burn, fume. Controls: hot work permit, fire watch 30 min post-work, extinguisher within reach.
7. Cleanup and demobilization. Hazards: residual nails, manual handling. Controls: magnetic sweep complete before crew leaves.

Commercial low-slope

Add: warning line systems (where allowed by 1926.501(b)(10)), parapet inspection, mechanical equipment isolation, roof access hatch control.

PPE list for a roofing JHA

• Hard hat (Type I or II depending on impact direction)
• Safety glasses Z87.1
• Hi-vis when working near vehicle traffic
• Full-body harness — ANSI Z359.11, with shock-absorbing lanyard or SRL
• Anchor connector rated to 5,000 lb static or 2× max arrest force
• Slip-resistant boots
• Leather palms for tear-off
• Hearing protection where power tools exceed 85 dBA
• Respirator (P100 or supplied air) where silica is in play

The residential fall protection plan exception

Under 1926.502(k), residential roofers may use a written fall protection plan when conventional fall protection (PFAS, guardrails, nets) is infeasible or creates a greater hazard. This is the most-misunderstood provision in Subpart M. The plan must:

• Be specific to the site and the work
• Document why conventional protection is infeasible at that location
• Specify the alternative measures
• Be approved by a qualified person
• Be available on site

"It's cheaper" and "we always do it this way" are not infeasibility arguments. OSHA inspectors know this verbatim.

Crew briefing and sign-off

Roofing JHAs are read at the morning huddle, signed by every crew member, and posted at the site. Conditions checked before the first ladder goes up — wind, temperature, surface condition. If conditions don't match the plan, the JHA stops the work until they do.

Build a roofing JHA in Riskora

The roofing JHA template in Riskora is pre-mapped to Subpart M, includes the residential fall protection plan structure, and produces sign-off-ready PDF output. Edit the steps to match your scope; the hazard library handles the standard hazards.

Related: JHA generator · JSA examples · JHA for welding & hot work