This section has been reviewed and updated as needed: September 2016

Policy Statement

This policy is to establish requirements for the safety of UNC employees and contractors while accessing roofs in various locations around campus. The purpose of the roof access policy is to establish a set of guidelines and requirements that UNC Environment, Health and Safety, supervisors, employees and contractors must uphold.

Definitions

Campus roof
The structure forming the upper covering of a campus building or parking deck
Chemical fume hood exhaust
Air expelled from a ventilation device used in laboratories to contain fumes, vapors, mists and particulate matter generated within the device
Radio frequency
A frequency or band of frequencies suitable for telecommunications; the frequency range extending from 3 kilohertz to 300 gigahertz.
Roof access
Obtaining admittance to a campus roof through a door, hatch or other means

Audience

UNC employees and contractors accessing campus roofs must be aware of and comply with this policy.

Reason for Policy

UNC employees and contractors must be aware of potential hazards associated with accessing campus roofs, and this policy has been developed to assist in mitigating those hazards.

Roles and Responsibilities

EHS is responsible for reviewing hazards and incidents associated with accessing campus roofs. EHS is responsible for reviewing and updating the Roof Access Policy. EHS and supervisors will also work jointly in the development of Job Safety Analysis for roof access issues that present a unique hazard to the employee. EHS will develop and implement the training for this policy.
It is the supervisor’s responsibility to make sure that employees who will be required to access campus roofs are properly trained on the Roof Access policy and other applicable policies upon employment. It is the supervisor’s responsibility to ensure that their employees adhere to the requirements of this policy.

Procedures

Roof access is currently restricted to staff and others that are issued a maintenance room key. With the implementation of this policy, access will be controlled by electronic card access systems for authorized staff and others trained on this policy. An individual’s UNC One Card, Medical School Photo ID badge, or electronic key box in campus housing facilities will be used to access roofs. Other equally effective access methods may also be considered with approval by EHS. The systems will be installed in phases:

  • Phase I will include buildings with RF antennas located on the roof.
  • Phase II will include laboratory buildings with short exhaust stacks.
  • Phase III will include the remainder of campus buildings based on potential hazards.

Contractors will be given temporary authorization to access campus roofs for projects requiring roof work through Construction Services and Management. Construction Services and Management will inform contractors of specific potential hazards on the roofs where the work will occur.

Individuals with access privileges must not provide their One Card, ID badge, or electronic key box passcode to anyone under any circumstances. Lost card, badges or keys must be reported immediately to the appropriate authorizing office to prevent any unauthorized use.

Unauthorized access is a violation of this policy and may violate other University policies or civil or criminal laws. Allowing unauthorized persons to access a roof will result in revocation of access privileges and/or disciplinary action.

Preplan all work including personal protective equipment (PPE) prior to the project.

  • Ask yourself the following questions:
    • What does this job require to complete?
    • What type of PPE will be needed?
    • Will fall protection be required?
    • Is there a partition or guardrail that is 42″ +/- 3? If Yes, fall protection is not required. If No, fall protection is required.
    • Is a fall protection system already installed on the rooftop? If Yes, a personal fall arrest system consisting of a harness and lanyard or harness and self-retracting lifeline is required. If No, and it is a sloped roof, roof access is denied. If No, and it is a flat roof, a Controlled Access Zone must be established.
    • Unsure about fall protection? Contact EHS personnel.
  • Pay attention to any posted safety signage at roof access point(s).
  • If rooftop activities might generate dust or odors in the vicinity of building air intakes, contact EHS for project review.
  • Assess work conditions– avoid or restrict roof access work when wet or windy weather conditions exist, especially after dark unless adequate illumination is available.
  • Inspect site & equipment for:
    • Structural integrity of the roof surface to safely support heavy equipment/tools
    • Condition of equipment (protective fall restraint system, personal protective equipment, etc.)
    • Potential insects/ pest problems on the roof (e.g., beehives, wasps, bird droppings, etc.)
  • For any roof safety concerns, contact supervisor or EHS at 919-962-5507.

During roof work:

  • Ensure safety down below — for work being performed close to the roof’s edge, demarcate and barricade the area(s) below to protect pedestrian from falling debris.
  • Pay extra attention to trip and slip hazards (i.e., standing water or equipment).

Completion of roof work:

  • General housekeeping– Prior to leaving the roof, clean up and remove all tools/equipment, and materials.
  • Never leave any items on the rooftop that can be blown off by the wind.
  • Secure the roof access door and/or hatch to prevent unauthorized roof access.
Campus roofs contain mechanical equipment with hazardous moving parts such as exhaust fans. Hazardous moving parts must be guarded to prevent accidental contact with the parts. Employees accessing roofs must be aware of equipment and machine guarding requirements outlined in the campus Machine Safeguarding Requirements Policy. Employees should report any equipment without safeguards in place. Maintenance and repair crew must never fail to replace the guards before the job is considered finished.
Employees accessing campus roofs must be aware of and adhere to fall protection requirements. The OSHA specific requirements are outlined in the campus Fall Protection Policy. A summary of some of the requirements are provided below:

  • Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.
  • Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems.
  • Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels by personal fall arrest systems, covers, or guardrail systems erected around these areas.
  • Each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system.
  • Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toe boards, safety net systems, or personal fall arrest systems.
Some campus roofs are only accessible via fixed ladders. Employees must be familiar with the campus Stairways and Ladders Policy. General ladder safety requirements are:

  • Ladder side rails shall extend at least 3 feet above the point of support at eave, gutter, or roof line.
  • Always maintain 3 points of contact with the ladder (ex. Two hands and one foot, two feet and one hand).
  • Clean grease, mud or other slippery debris off shoes prior to climbing ladder.
  • Always face ladder when climbing up or down.
  • Never slide down a ladder.
  • Carry tools in pouch around waste and/or use rope to raise or lower large items to or from roof.
Employees working on the campus roofs may be exposed to unfavorable weather conditions such as extreme heat or cold temperatures. Employees should:

  • Wear appropriate clothing. Choose lightweight, light-colored, loose-fitting clothing in hot conditions. Choose layers of loose-fitting, insulating and possibly waterproof clothes in cold conditions.
  • When working in the heat, stay hydrated by drinking small amounts of cool water frequently. Drink warm, sweetened liquids in the cold.
  • Monitor yourself and co-workers for symptoms of weather-related illness. Call 911 immediately if symptoms are observed.
  • Review the campus Heat Stress Policy.
Chemical fume hood exhausts are located on the roofs of campus laboratory buildings. The risk of exposure to chemical substances in concentrations that exceed occupational exposure limits for individuals working on roofs is extremely low due to the large amount of dilution that occurs in a laboratory hood and further dilution when the exhaust gases mix with the surrounding air. For further protection, exhaust stacks are designed to have enough velocity and height (typically 10 ft.) to exhaust above the building envelope to prevent re-entrainment. The majority of campus fume hood exhausts meet these requirements. There are a limited number of buildings with short exhaust stacks where there is a possibility of re-entrainment. EHS will work conjointly with Facilities Services to identify these buildings and post warning signs at the access points.

When working on roofs with short stacks, individuals should maintain at least a 10 foot radius around the exhaust. If you have to work within 1 0 feet of the exhaust, contact the laboratory to coordinate shut down of the fume hood during the work. Place an out-of-service sign on the fume hood. If the fume hood cannot be shut down, contact EHS (919-962-5507) for assistance in determining the proper procedures and personal protective equipment (PPE) to wear during the work.

Currently fourteen roofs have network carrier antennas as part of the Neutral Hosting/Distributed Antenna System initiative which is an effort to provide cellular coverage across campus. Additional antennas will be added in phases. Six of the current antennas have the potential to transmit radio frequency (RF) emissions above occupational exposure limits. These antennas are in designated controlled areas surrounded by barriers to prevent exposures above RF limits for people accessing the roofs. Safety signs are posted at roof access points and on the barriers around the antennas. Employees must obey all posted signs, assume antennas are transmitting and not enter the prohibited area around antennas. EHS will develop a RF safety program to provide guidelines on variables that include:

  1. required distance from RF transmitting equipment,
  2. intensity of the RF emissions, and
  3. duration of exposure.

The program will be in Appendix A of this policy. Employees accessing the roofs must be trained on the Roof Access Policy as well as RF safety requirements. The current RF antenna buildings are listed below:

  • Administrative Office Building (AOB – Giles Horney complex)*
  • Cardinal Parking Deck
  • Carmichael Residence Hall*
  • Cobb Parking Deck
  • Dean Smith Center
  • Ehringhaus Residence Hall
  • FedEx Global Education Center*
  • Greenlaw
  • Hinton James Residence Hall
  • ITS Manning*
  • Kenan-Flagler Parking Deck
  • Kenan Music Center*
  • Kenan Stadium*
  • Morehead Planetarium

*locations where occupational limits may be exceeded within the controlled areas

UNC-CH shall provide a one-time training program for each employee who might access campus roofs. Individuals must be trained on this policy before authorization will be provided. Personnel who access any roofs must be trained on general safe practices that are relevant to their work, including but not limited to the following:

  1. Overview of potential roof hazards
    1. General roof safety
    2. Machine guarding
    3. Fall protection
    4. Ladder use
    5. Environmental conditions
    6. Chemical fume hood exhaust
    7. Radio frequency safety
  2. Roof access authorization requirements
Circumstances where retraining is required include, but are not limited to, situations where:

    1. An incident in the workplace has occurred that is associated with roof access.
    2. Changes in the workplace render previous training obsolete.
    3. Changes in this policy.
    4. Inadequacies in an affected employee’s knowledge indicate that the employee has not retained the requisite understanding of this policy.

Related Regulations, Statutes and Related Policies

  • Section 5(a)(1) of the Occupational Safety and Health Act of 1970, General Duty Clause
  • Federal Communications Commission 47 CFR 1.1310 Radiofrequency Radiation Exposure Limits Standard
  • North Carolina General Statutes, Chapter 95, Article 16, Occupational Safety and Health Act of North Carolina

Policy Contact

Kim Haley, Certified Industrial Hygienist
Department of Environment, Health and Safety
Phone: 919-843-2735
Email: kphaley@ehs.unc.edu


Appendix A: Radio Frequency Safety

This section will be added in the future and will include:

  • Health Hazards of Radio Frequency (RF) Emissions
  • Specific Information on Campus RF Transmitting Antennas
    1. Required distance from RF transmitting equipment
    2. Intensity of the RF emissions
    3. Duration of exposure
  • Applicable RF Regulations