Roof Safety for Inspectors: Balancing Risks and Opportunities
Roof inspections are a critical component of commercial and home property evaluations, providing essential insights into the condition of a building’s roofing system. However, accessing and inspecting roofs poses significant safety risks for inspectors, particularly when navigating the distinct requirements and challenges of residential versus commercial properties.
While Calibre is a commercial inspection company, nearly all of our inspectors started in the residential inspector role. As I (Paul Duffau) personally know four inspectors who faced serious injury from roof and ladder accidents, we’re going to take the time to explore roof safety considerations for home and commercial inspectors. To do so, we’re highlighting regulations from the controlling organizations, the Occupational Safety and Health Administration (OSHA) in Idaho and Washington State’s Department of Occupational Safety and Health (DOSH), the inherent risks of traversing the roof, and the opportunities to deliver valuable information to clients. We draw on the Washington State Home Inspection Standard of Practice, the InterNACHI Standards of Practice, and the CCPIA Standards of Practice to provide a comprehensive framework.
So, let’s move on.
Understanding the Roles: Commercial Inspectors vs. Home Inspectors
Commercial and home inspectors operate under different scopes of work, standards, and expectations, which directly influence their approach to roof safety.
Commercial Inspectors: The CCPIA Standards of Practice (ComSOP) define commercial inspections as evaluations of building structures and improvements on commercial real estate, such as offices, retail centers, or multi-unit residential buildings operated for profit. Commercial roof inspections often involve low-slope or flat roofs, which differ from the steeper residential roofs. The ComSOP requires inspectors to follow a scope agreed upon with the client, which may include walking the roof if safe and accessible, but does not mandate exhaustive testing or specialized equipment (Section 4.3, CCPIA ComSOP). Unlike home inspections, commercial inspections may involve larger, more complex roofing systems, requiring additional safety considerations and expertise.
Home Inspectors: According to the Washington State Home Inspection Standard of Practice (WAC 308-408C), home inspectors are required to traverse the roof to perform inspections of roofing materials, drainage systems, flashings, skylights, chimneys, and roof penetrations unless doing so could cause damage or pose a safety hazard (WAC 308-408C-030). The InterNACHI Standards of Practice similarly emphasize a non-invasive approach, requiring inspectors to observe roof coverings, drainage systems, flashings, and chimneys from accessible areas, but explicitly state that inspectors are not required to walk roofs if it is unsafe or could cause damage (Section 3.1, InterNACHI SoP).
The distinction in scope means home inspectors focus on residential systems with a standardized approach, while commercial inspectors often tailor inspections to client needs, potentially requiring more extensive roof access and specialized knowledge of commercial roofing systems, such as built-up roofing (BUR) or single-ply membranes.
OSHA and DOSH Safety Regulations for Roof Inspections
Both commercial and home inspectors must comply with safety regulations set by OSHA at the federal level and DOSH in Washington State, which has its own occupational safety standards under the Washington Industrial Safety and Health Act (WISHA).
OSHA Requirements (Idaho & Montana): OSHA’s regulations, particularly under 29 CFR 1926.501(b)(10) for low-slope roofs, mandate fall protection for workers, including inspectors, when working at heights above six feet. For commercial roofs, OSHA introduced a rule effective November 2017, requiring top ridge anchors for attaching safety cords or fall-arrest systems for anyone walking or inspecting pitched commercial roofs (OSHA 1910.28). This applies to commercial property inspectors who choose to walk roofs, requiring the use of personal fall-arrest systems, guardrails, or safety monitoring systems when guardrails or safety monitoring systems. For inspections, OSHA allows an exception for short-duration, pre- or post-construction inspections where no construction activity is occurring, as the lack of ongoing work reduces distractions and fall risks. However, this exception does not eliminate the need for caution or compliance with local codes.
Washington State DOSH Requirements: DOSH aligns with OSHA but often imposes stricter standards under WISHA. For example, WAC 296-876 outlines ladder safety requirements, mandating proper ladder setup, secure footing, and fall protection when working at heights. WAC 296-880 generally requires fall protection systems, such as guardrails or personal fall-arrest systems, for any work above four feet in general industry settings. However, WAC 296-880-20010 provides an exception for low-slope roofs (defined as having a slope of 4:12 or less) during inspection activities. Under this exception, inspectors are not required to use fall protection systems if the work is of short duration, performed by a qualified person, and conducted away from fall hazards (e.g., at least six feet from the roof edge). If inspectors work closer to the edge or on steeper roofs, fall protection, such as harnesses or guardrails, is mandatory. DOSH also emphasizes training and hazard assessments, requiring inspectors to be trained in recognizing and mitigating fall risks before accessing roofs. This training is critical for both home and commercial inspectors, particularly on complex commercial roofs with unguarded edges or equipment.
Risks for Inspectors
Roof inspections present several risks, which vary depending on whether the inspection is residential or commercial:
Falls: The most significant risk for both home and commercial inspectors is falling from heights, especially on steep residential roofs or low-slope commercial roofs with unguarded edges. The InterNACHI Standards and CCPIA ComSOP explicitly allow inspectors to avoid walking roofs if it poses a safety hazard, emphasizing observation from safe vantage points like ladders or the ground. DOSH data indicates that falls are a leading cause of workplace injuries in Washington, underscoring the need for fall protection compliance.
Roof Damage: Walking on fragile or deteriorated roofs, such as those with brittle shingles or compromised membranes, can cause damage, leading to liability issues. Home inspectors are cautioned against walking roofs that may be damaged (WAC 308-408C-030), while commercial inspectors must assess roofing materials like BUR or EPDM, which may conceal weak spots.
Weather and Environmental Hazards: Inspectors face risks from weather conditions (e.g., wet or icy roofs) and environmental factors like loose debris or electrical hazards from roof-mounted equipment. Commercial roofs often have HVAC units, exhaust fans, or skylights, increasing the complexity and risk of navigation.
Access Challenges: Accessing commercial roofs, often via fixed ladders or hatches, can be more hazardous than residential roofs, which typically involve portable ladders. Improper ladder use or unsecured access points can lead to falls or injuries.
So, why should we attempt to traverse a roof?
Opportunities for Delivering Valuable Information
Despite the risks, roof inspections provide significant opportunities to deliver critical information to clients, enhancing the value of the inspection:
Commercial Inspections: The CCPIA ComSOP encourages inspectors to tailor reports to client needs, which may include detailed assessments of roof systems, membrane integrity, or drainage performance. Commercial clients, such as property managers or investors, can benefit from cost-to-cure tables that estimate immediate repair costs,. Inspectors can also identify energy efficiency issues, such as poor insulation or leaking membranes, which impact operational costs and habitability.
Home Inspections: The Washington State Home Inspection Standard and InterNACHI Standards require inspectors to report on roof coverings, drainage systems, flashings, and penetrations, identifying defects like missing shingles, improper flashing, or poor drainage. These findings help clients understand maintenance needs, estimate repair costs, and assess the roof’s remaining lifespan. For example, identifying wind or hail damage can support insurance claims, while noting poor drainage can prompt preventive measures to avoid water intrusion.
Client Education: Both home and commercial inspectors can educate clients on maintenance practices, such as clearing debris from gutters or scheduling regular roof maintenance, reducing long-term costs. By adhering to standards and leveraging training, inspectors can provide actionable recommendations without overstepping into prescribing repair methods, which is outside the scope of both InterNACHI and CCPIA standards.
Best Practices for Safe Roof Inspections
To balance safety and the delivery of valuable information, inspectors should adopt the following practices:
Pre-Inspection Planning: Assess roof accessibility, weather conditions, and material condition before climbing. Use drones (Calibre Commercial Inspections has FAA-certified drone pilots) or binoculars for steep or unsafe roofs, as permitted by InterNACHI and CCPIA standards.
Compliance with OSHA and DOSH: Use fall protection systems, such as harnesses or guardrails where required, especially on commercial roofs. Conduct hazard assessments per DOSH requirements.
Training and Education: Calibre Commercial Inspections maintains a training program and company-specific Standard of Practice for ladder safety and roof inspections. Any company that you contract with should have the same. We recommend asking.
Clear Communication with Clients: Define the scope of the roof inspection in writing, as recommended by CCPIA’s ComSOP, to manage expectations and clarify limitations, especially for commercial clients with specific needs.
Documentation: Provide detailed, written reports as required by all three standards, including photos and descriptions of defects. For commercial inspections, include cost-to-cure estimates or refer clients to specialists for further evaluation.
Conclusion
Roof inspections are a high-risk, high-reward aspect of commercial property evaluations. Commercial inspectors, under the CCPIA ComSOP, tackle more complex roofing systems with tailored scopes, requiring heightened safety measures. OSHA and DOSH regulations mandate fall protection and hazard awareness, with DOSH enforcing stricter standards in Washington State. Despite risks like falls, roof damage, and environmental hazards, inspectors can deliver valuable insights into roof condition, maintenance needs, and cost estimates, empowering clients to make informed decisions. By adhering to standards, leveraging training, and prioritizing safety, inspectors can mitigate risks while maximizing the value of their reports.