Categories: Construction, Safety

Roofing Construction Toxicity and Flammability Hazards

TASA ID: 3404

In order to reduce energy costs in roofing construction, contractors install cool roofs1 aka Single-Ply Roofing, as estimated by Bob Craig in EDC Magazine, "The majority of new roofing is a white single-ply membrane, either TPO (thermoplastic polyolefin) or PVC (polyvinyl chloride). This is due mostly to new energy codes that require reflective roofing to reduce heat absorption into the structure.”

A consequence of cool roofing requires roofing construction workers to use highly flammable solvents and adhesives to glue down the membrane to the roof substructure.  Historically, the use of chemical products by roofing workers had been fairly limited to propane, hot asphaltic tar or rubber, and light gravel. Today’s single-ply roofing involves the adhesion of an impervious roofing membrane by adhesives and solvents which are extremely flammable and some toxic.  In addition to the flammability factor, there is a strong potential for adverse health exposure should workers handle products improperly, especially if safety training and personal protective equipment (PPE) are inadequate or not provided by the employer and readily available.  The following overviews are accounts taken from recent roofing construction safety initiatives, and inspections conducted on commercial roofing and apprenticeship training site.

Case Studies

Risk Control Initiative
To control the cost of workers’ compensation insurance, a group of roofing contractors established an alternative dispute resolution (ADR) program. The ADR program mandated contractors comply with two annual field safety inspections.  When the inspection was completed, a photo safety report was sent to each contractor, including the specific regulatory violation identified, and simple recommendations for improving safety.  After several years, the violations began to pile up, and due to a confidentiality clause, no oversight of the inspection process was put in place. Contractors simply disregarded the reports, throwing them away and neglecting to correct the violations.  In a final effort to reduce the egregious amount of repeated safety issues, the inspection team sent out a notification to each company, but ultimately the inspector was replaced with a more lenient observer.

Roofing Construction Injury
High above a school gymnasium a construction worker installs a white roofing membrane, while cleaning the materials with a damp rag and a highly flammable solvent.  As work continues, the roofer became drowsy and decided to take a break, so he climbed down the roof ladder. 

During his decent, he began to lose consciousness, lost grip of the ladder, falling to the concrete deck below. The ensuing investigation revealed that the roofing contractor was unaware that the highly toxic and flammable solvent being used (a standard roofing trade product) had the potential to provoke unexpected consequences and secondary injury, like the fall from the ladder.

It was later discovered that the contractor had never provided respiratory protection or adequate safety training to the worker, which directly resulted in serious injury requiring months of rehabilitation, lost wages and painful physical therapy.
Roofing Apprenticeship Center Safety Issues
During a fire and chemical safety inspection at a new roofing apprenticeship training center, multiple flammable, toxic, and hazardous chemical products were discovered throughout the facility.  A number of unlabeled and open chemical products had been placed on the floor, flammable gases and products stored unprotected on open shelving or placed in boxes, or in areas where students were being trained.  Upon the close of the inspection, it was noted that the facility did not have a hazard communication program (HazCom), Safety Data Sheets (SDS)/ safe chemical inventory, or a fire response and emergency action plan (EAP).  Post safety inspection recommendations included installation of new flammable storage cabinets, OSHA signage, an update to required written programs, and a site-specific SDS chemical inventory be developed and readily available.

The Other Hazards of Handling Flammable Liquids
As Michael Polkabla, a Certified Industrial Hygienist (CIH) explains, “To protect workers who use and handle flammable solvents on the jobsite, we must always remember that beyond the obvious hazards of fire and explosion, there are other factors that directly influence the worker’s health and safety.  Virtually all flammable solvents that are used in construction can also cause physical harm through the breathing of vapors, contact with skin, accidental ingestion, and even injection into the skin. Inhalation of solvent vapors occurs mainly through use of such products with limited ventilation; however, even on a rooftop, such exposures may be at harmful levels.  That is why it is important to know the hazards of the solvents you are working with (for example, refer to the SDS) and to take the appropriate precautions such as use of a respirator, using adequate ventilation, working upwind, etc.”

Expert Interface
Experts selected to serve roofing construction cases need to be experienced, proficient, and highly knowledgeable regarding the roofing construction industry, safety practices and known hazards specific to the roofing trade. They must also have experience in conducting roofing jobsite safety inspections, a working knowledge of roofing worker habits, and well-versed in the specific OSHA regulations governing roofing construction and investigative report conclusions.  The expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue for roofing injury or illness.  

Roofing safety experts serve counsel as well-versed safety practitioners when they possess actual experience in roofing safety and construction, with the capacity to decipher, and then convey complex regulatory standards and principles. Experts must be able to research case documents, provide in-depth deposition testimony, decode photographic evidence, and provide a cogent report.  Experts can also be instrumental by developing convincing graphs, charts, models and highly detailed analysis, in addition to their conclusive and well supported professional opinions.  

Roofing contractors, educators and risk managers must be held responsible for ensuring projects are safe, workers are trained and provided with adequate personal protective equipment (PPE). Building contractors must also be responsible for conducting reasonable and appropriate site safety and health inspections with timely follow up and accountability for unsafe acts by their workers correcting unsafe conditions as they are found.  Information gleaned from site safety inspection reports can serve as a valuable resource for foremen and superintendent safety advisories, and can be brought onto the jobsite to improve safety culture and a proactive worker training tool.


EPA Cool Roof

White Single Ply Roofing Membrane, Not so Fast, Craig, B., February 2014, EDC Magazine

The Other Hazards of Handling Flammable Liquids, Polkabla, M, November 2010, Lessons Learned
SAFETRAN, LLC, Editor Daniel J. O’Connell, Roofing Construction Safety Newsletter 

Hazard Communication Standard (HCS)
OSHA 29 CFR 1910.1200

Emergency Action Plans
OSHA 29 CFR 1910.38

Hazard Communication Standard, California
CCR, Title 8, §5194

Emergency Action Plan Standard, California
CCR, Title 8, §3220

This article discusses issues of general interest and does not give any specific legal or business advice pertaining to any specific circumstances.  Before acting upon any of its information, you should obtain appropriate advice from a lawyer or other qualified professional.

This article may not be duplicated, altered, distributed, saved, incorporated into another document or website, or otherwise modified without the permission of TASA.

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