PV Installation Hazards and Mitigation

In an increasingly competitive PV marketplace, project managers and installation forepersons regularly face tight project budgets and narrow installation time frames. Considering these pressures, developing safety procedures, scheduling the associated training and then implementing and enforcing the programs on the jobsite may seem unnecessarily burdensome. However, making worker safety a priority is not optional. It is imperative for your business and for the PV industry as a whole. Integration teams need to clearly understand the difference between what might be considered common sense approaches that provide a minimum level of safety on-site and being in compliance with the law. Safety programs should always be conscientiously developed to meet the requirements of the latter.

Professionals tasked with site safety program development and implementation must thoroughly research the laws and regulations of the Occupational Health and Safety Administration (OSHA) to determine which are applicable to the work being performed (see “Implementing a Successful Safety Program,”). You must not only understand, communicate and enforce these regulations, you must also be certain your employees adhere to them to keep themselves and their coworkers safe. While the full breadth of common hazards PV installers face cannot be sufficiently detailed in a single article, here I present several toplevel concerns that you should consider and address. Future SolarPro articles will delve into some of the topics introduced here in greater detail. My intent is to make you aware of the laws that govern the work you do and to motivate you to take the steps necessary to increase the overall safety of your installation teams.

Fall Hazards

While falls are obvious hazards PV installers face, standards dealing with fall protection are among the most commonly misunderstood and violated OSHA regulations. Low-slope roofs and pitched roofs present different challenges. The applicable solutions depend on several variables, including regional OSHA fall protection regulations, the pitch of the roof, the size and location of the work area, the height of the roof, the roofing material and the presence of additional openings on the surface, such as skylights. You must also consider the load capability of the roof, the number of workers present, the weight of the workers, the workers’ level of fall-protection competence, the availability and location of qualified anchoring points, parapet heights and many other details.

Navigating these variables to execute the proper fall protection system requires planning, training and a competent person to design and implement the fall protection system. According to OSHA, a competent person is defined as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” [Standards 29 CFR, 1926.32( f)]. OSHA’s website includes the following additional details: “By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met by the competent person.” This somewhat vague description leaves the responsibility of qualifying a person as competent to the discretion of the company, without defining any criteria for testing or external certification.

More complicated fall protection systems, such as horizontal lifelines, require the designer to be a qualified person—who, as defined by OSHA, is a person with a higher level of experience and expertise than a competent person. OSHA defines a qualified person as “one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” Numerous companies across the country offer fall-protection courses designed to train individuals to meet the qualified person–level requirements.

According to OSHA’s hierarchy of control, the first option to consider in a fall protection system should be to eliminate the hazard. For low-slope roofs with low parapets, this is best accomplished with guard rails to physically prevent workers from easily accessing locations that present a fall hazard. The use of traffic cones and caution tape as a lowcost warning line system is a common practice. However, this method satisfies neither OSHA’s hierarchy of control nor the formal requirements of a warning line system and could have serious consequences if a worker is hurt. Guardrails are a higher level of protection and should be used whenever possible. A properly designed warning line system that complies with the provisions in OSHA Standard 29 CFR, 1926 Subpart M, 1926.502( f) is a possible alternative if guardrails cannot be utilized.

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