Roofing Activity Hazard Analysis
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Roofing operations consistently rank among the most hazardous construction activities in the United States. The Bureau of Labor Statistics reports that roofers experience fatal work injuries at a rate more than three times the national average for all occupations, with falls from elevation accounting for the vast majority of these fatalities. On USACE and Department of Defense construction projects, roofing work requires a detailed Activity Hazard Analysis (AHA) under EM 385-1-1 before any worker steps onto a roof surface.
Roofing AHAs must address the full spectrum of hazards unique to elevated work on sloped and flat roof systems: fall protection system selection and installation, weather exposure including heat stress and lightning, material handling at height, hot work for built-up roofing systems, chemical exposure from adhesives and coatings, and the structural integrity of the roof deck itself. Each of these hazards requires specific controls documented in the AHA and briefed to every crew member before work begins.
This AHA template covers common roofing activities on USACE projects including tear-off, deck repair, membrane and shingle installation, flashing, and final inspection. It incorporates EM 385-1-1 fall protection requirements from Section 21.C, PPE requirements from Section 06.A, and the RAC matrix methodology for documenting risk reduction from initial to residual levels.
Disclaimer
This content is provided for general informational and educational purposes only. It is not a substitute for a site-specific Job Safety Analysis conducted by a qualified safety professional familiar with your workplace conditions, equipment, and personnel. OSHA citations, BLS statistics, and hazard controls referenced here may not reflect the most current standards or apply to your specific situation. Always consult current OSHA regulations, manufacturer guidelines, and a competent person before beginning work. Health & Safety Systems LLC assumes no liability for actions taken based on this content.
Definable Feature of Work (DFOW)
Roofing Installation & Repair
All roofing activities including tear-off of existing materials, deck inspection and repair, installation of underlayment, membranes, shingles, metal panels, or built-up systems, flashing installation, and final waterproofing verification.
Typical Duration: 1-6 weeks
EM 385-1-1 References
Section 21.C: Fall Protection — Roofing Work
Establishes fall protection requirements for roofing activities including trigger heights, system selection criteria for low-slope vs. steep-slope roofs, and monitoring system restrictions.
Section 06.A: Personal Protective Equipment — General
Requires hazard assessment to determine appropriate PPE for roofing work, including head protection, foot protection, eye protection, and fall protection equipment selection.
Section 21.A: Fall Protection — General Requirements
General fall protection requirements applicable to all construction activities with exposure to falls of 6 feet or more, including AHA documentation of fall protection plans.
Section 10.B: Welding, Cutting, and Brazing
Applies when hot work is performed during built-up roofing (BUR) or modified bitumen installation. Requires hot work permits and fire watch procedures.
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Start Free TrialRisk Assessment Code (RAC)
The RAC matrix combines hazard severity and probability to assign a risk level before and after controls are applied. This AHA demonstrates risk reduction from initial to residual conditions.
Initial Risk (Before Controls)
Extremely High (1)
Severity: Catastrophic | Probability: Likely
Residual Risk (After Controls)
Low (5)
Severity: Marginal | Probability: Seldom
Step-by-Step AHA Breakdown
Step 1: Establish fall protection perimeter and access controls
Hazards
- Falls from roof edge
- Unauthorized access to fall zone
- Unstable roof edge conditions
Controls
- Install warning line system at least 6 feet from roof edge
- Erect guardrail systems at all open edges and penetrations
- Post controlled access zone signage
- Designate and mark safe access points
Step 2: Set up material staging and hoisting
Hazards
- Struck-by falling materials
- Overloaded roof structure
- Crane/hoist tip-over
- Manual lifting injuries
Controls
- Verify roof structural capacity before material staging
- Use mechanical hoisting for materials over 50 lbs
- Establish exclusion zone below hoisting operations
- Distribute material loads per structural engineer guidance
Step 3: Remove existing roofing materials (tear-off)
Hazards
- Falls through deteriorated deck
- Exposure to asbestos or lead paint
- Flying debris from power tools
- Heat stress during summer operations
Controls
- Test for asbestos/lead before tear-off; abate if present
- Inspect deck integrity continuously during tear-off
- Cover or barricade any soft spots or openings immediately
- Implement heat illness prevention program per OSHA guidelines
Step 4: Inspect and repair roof deck
Hazards
- Falls through weakened deck sections
- Structural collapse
- Nail/screw puncture injuries
Controls
- Competent person inspects entire deck before workers proceed
- Replace deteriorated decking before loading with new materials
- Mark unsafe areas with warning tape and hole covers
- Workers wear puncture-resistant footwear
Step 5: Install underlayment and vapor barriers
Hazards
- Slips on smooth membrane surfaces
- Chemical exposure from adhesives
- Burns from hot-applied materials
Controls
- Wear slip-resistant footwear rated for membrane surfaces
- Provide ventilation for adhesive application in enclosed areas
- Follow hot work permit requirements for torch-applied membranes
- Keep fire extinguisher within 20 feet of hot work
Step 6: Install roofing system (shingles, membrane, metal, or BUR)
Hazards
- Falls from sloped surfaces
- Nail gun injuries
- Repetitive motion strain
- Heat stress
- Burns from hot asphalt (BUR systems)
Controls
- Use personal fall arrest systems on slopes greater than 4:12
- Follow pneumatic tool safety procedures per manufacturer
- Rotate workers to prevent repetitive strain injuries
- Schedule heavy work for cooler parts of day
- Hot asphalt kettles positioned per EM 385 setback requirements
Step 7: Install flashing, drip edges, and penetration seals
Hazards
- Falls at roof edge during edge work
- Cuts from sheet metal
- Eye injuries from metal cutting
Controls
- 100% tie-off required for all edge work
- Wear cut-resistant gloves when handling sheet metal
- Wear safety glasses with side shields during metal cutting
- Use aviation snips instead of grinders when possible
Step 8: Conduct water testing and final inspection
Hazards
- Slips on wet roof surface
- Electrical hazards from ponding water near equipment
- Falls during inspection walkthrough
Controls
- Wear slip-resistant footwear during water testing
- Keep electrical equipment clear of water test areas
- Maintain fall protection until all workers are off the roof
- Competent person performs final inspection walkthrough
Step 9: Demobilize equipment and remove fall protection
Hazards
- Falls during guardrail removal
- Struck-by during material lowering
- Housekeeping hazards from remaining debris
Controls
- Remove fall protection last — workers use personal fall arrest until guardrails are the final item removed
- Lower materials mechanically; do not throw from roof
- Conduct final housekeeping sweep before demobilization sign-off
Competent & Qualified Persons
EM 385-1-1 requires designated competent and qualified persons for specific activities. These individuals must have the training, experience, and authority to identify hazards and take corrective action.
Competent Person — Fall Protection
Must be able to identify fall hazards, select appropriate fall protection systems, and have authority to take corrective action including stopping work. Must complete fall protection competent person training and be designated in writing by the employer.
EM 385-1-1 Reference: Section 21.A.02
Competent Person — Roofing
Experienced in roofing operations with knowledge of roof structural capacity, material staging limitations, and weather-related hazards. Responsible for daily crew briefings and AHA review.
EM 385-1-1 Reference: Section 01.A.17
Site Safety and Health Officer (SSHO)
Must hold 30-hour OSHA construction course and EM 385-1-1 40-hour training. Responsible for reviewing and approving the roofing AHA, conducting site inspections, and maintaining safety documentation.
EM 385-1-1 Reference: Section 01.A.17
Equipment, Training & Inspection Requirements
Required Equipment
Training Requirements
- USACE EM 385-1-1 40-hour safety training
- OSHA 10-hour or 30-hour construction safety
- Fall protection competent person training
- Personal fall arrest system inspection and use
- Hot work permit procedures (if applicable)
- Heat illness prevention training
Inspection Requirements
- Daily fall protection equipment inspection before each use
- Daily roof deck inspection by competent person before workers access roof
- Pre-shift safety briefing covering AHA and current conditions
- Weekly documented safety inspection by SSHO
- Post-weather event inspection (rain, wind, lightning)
Applicable OSHA Standards
29 CFR 1926.501
Duty to Have Fall Protection
Requires fall protection for workers on walking/working surfaces with unprotected edges 6 feet or more above a lower level. Specific provisions for roofing work on low-slope and steep-slope roofs.
29 CFR 1926.502
Fall Protection Systems Criteria and Practices
Specifies performance and construction requirements for guardrail systems, safety net systems, personal fall arrest systems, and warning line systems used in roofing.
29 CFR 1926.503
Training Requirements
Requires employers to provide fall protection training for each worker exposed to fall hazards. Training must cover recognition of hazards and procedures to minimize them.
29 CFR 1926.451
Scaffolding — General Requirements
Applies when scaffolding is used for roof access or edge work. Requires competent person design and daily inspection of all scaffolding systems.
Required Personal Protective Equipment
Frequently Asked Questions
When is an AHA required for roofing work on a USACE project?
An AHA is required before any roofing work begins on a USACE or DoD construction project governed by EM 385-1-1. The AHA must be prepared by the roofing contractor, reviewed by the Site Safety and Health Officer (SSHO), and approved before workers access the roof. A separate AHA is required for each distinct roofing phase if hazards differ significantly.
What fall protection is required for roofing under EM 385-1-1?
EM 385-1-1 Section 21.C requires fall protection for all roofing workers exposed to falls of 6 feet or more. On low-slope roofs (4:12 or less), options include guardrail systems, warning line systems combined with personal fall arrest, or safety monitors combined with warning lines. On steep-slope roofs (greater than 4:12), personal fall arrest systems or guardrails are required.
What is the difference between low-slope and steep-slope roofing fall protection?
OSHA and EM 385-1-1 define low-slope roofs as having a slope of 4:12 (18.4 degrees) or less, and steep-slope roofs as anything greater. Low-slope roofs allow more fall protection options including warning line systems and safety monitor systems. Steep-slope roofs require either personal fall arrest systems or guardrail systems.
How do you calculate the RAC for roofing operations?
The Risk Assessment Code (RAC) combines severity and probability using the EM 385-1-1 matrix. For roofing without controls, the initial assessment is typically Catastrophic severity with Likely probability, yielding RAC 1 (Extremely High). After implementing fall protection, the residual risk typically drops to Marginal severity with Seldom probability, yielding RAC 5 (Low).
Can a safety monitor system be used alone for roofing on USACE projects?
No. EM 385-1-1 does not allow a safety monitor system as the sole means of fall protection for any roofing activity. On low-slope roofs, a safety monitor may be used in combination with a warning line system, but never alone. On steep-slope roofs, safety monitor systems are not permitted at all.