Roofing job hazard analysis, drafted from a roof-work photo

A roofing JHA has to reconcile four related fall-protection rules, and they answer different questions. 29 CFR 1926.501 is the duty clause — it says that above six feet on a construction surface, workers must be protected from falling, and it is the standard most roofing JHAs are really about. 1926.502 is the criteria: if you use a guardrail, a personal fall arrest system, or a safety net, this is how strong and how configured it has to be, which is why a harness clipped to an un-rated anchor is not compliance, it is a photo of a harness. 1926.1053 governs the ladder that gets the crew up there, and 1926.503 requires that the people using all of this were trained to recognize the hazards. A JHA that names only the duty clause and skips the criteria is the kind of document that looks finished and protects no one.

Steep-slope roofing carries its own history. OSHA once allowed a slide-guard-and-monitor approach for residential roofing under a directive, but that interim policy was rescinded, and residential roofers are now expected to meet the conventional fall-protection requirements of 1926.501 unless an employer can document that those methods are infeasible or create a greater hazard and then follow a written fall-protection plan built to 1926.502(k). That is exactly the kind of judgment a photo cannot make for you — the scan can flag that a crew is on a steep slope with no visible protection, but whether a written plan is justified is a competent-person decision.

Falls through skylights and unguarded roof openings are a recurring source of roofing fatalities, and they are uniquely dangerous because the hazard is often invisible from above — a skylight domed just enough to look walkable, or a panel laid over a hole that reads as solid decking in a photo. OSHA treats a skylight as a hole: 1926.501(b)(4) requires that workers be protected from falling through holes and skylights, and 1926.502(i) sets the criteria for covers, including that they be secured, marked, and able to support the loads they will see. A cover that is not labeled and not fastened is not a control; it is a trap.

The scan can flag a skylight that appears uncovered, unmarked, or covered with something that does not look load-rated, and it will say so as a possibility, not a verdict — because from a single frame it cannot confirm what is under the panel or how it is fastened. That is precisely the finding to walk to and verify: lift nothing, but confirm the cover is secured, rated, and marked, or that a guardrail or fall arrest protects the opening. It is one of the highest-severity, easiest-to-miss items on any roof.

A camera on a roof captures geometry, not ratings. It can show a lifeline running to an anchor point; it cannot tell you the anchor is rated for 5,000 pounds per worker or was installed to the manufacturer's instructions. It can show a ladder at the eave; it cannot feel whether the footing is secure or measure the 4-to-1 angle precisely. It cannot sense the wind that turns a sheet of underlayment into a sail, read the heat index that is cooking the crew on a black membrane, or know that the decking under a patched area is rotten. And OSHA cites conditions, not paperwork — a flawless roofing JHA for a crew with no real fall protection helps no one.

So treat the scan as the fastest possible first pass for visible fall-protection gaps, then do the walk. Photograph the setup, read the drafted findings, verify each one on the roof, add the anchor ratings, deck condition, weather, and training that no frame can show, and keep the dated report. Try that loop on a photo of your own roof job below — the scan is free and takes about a minute.