Part 1 of this series looked at working at height risks specific to residential solar panel cleaning, what OSHA has to say about working at height, the Hierarchy of Fall Protection, what bearing this has on solar panel cleaners. The guidance is broken down into 4 steps, the first of which is in Part 1: Eliminate the Need For Working At Height Where Possible and why cleaning from ground level should be the go-to option on all jobs. For reference during this article, here is the Hierarchy of Fall Protection again:
Part 2 will now discuss how solar panel cleaning can be done safely if working from ground level is not possible.
Step Two: What Engineering Controls Can Be Used To Reduce Works at Heights?
Engineering controls are those that are built into the design of the building, equipment, materials or other aspects of the work environment. These can take the shape of fixed or stationary guardrails. These are preferable as they do not rely on a worker being trained and using a harness or other form of fall protection.
Other examples of engineering controls may be rooflight covers to prevent a fall through a rooflight, fixed or suspended scaffolding or mobile elevated working platforms (MEWPs).
Engineering controls should be used wherever possible. However, guardrails and rooflight covers will not be installed on homes. However, fall protection techniques for solar panel cleaning on residential properties are available and should always be used.
Residential solar panel cleaning should never be attempted on an open-edged roof without a fall protection plan in place and without suitable PPE being used, specifically a full body harness and lanyard or rope system.
Where residential solar panels cannot be reached from ground level what options should be considered?
- Use an A-frame ladder. If your water-fed pole has enough length to reach the solar panels, but the wrong angle, an A-frame ladder positioned at ground level can assist in cleaning the solar panels by adjusting the angle of the pole. Providing the height worker on the ladder is no more than 4 feet, this is a safe working method.
- Use a MEWP. Cleaning solar panels from a MEWP is often possible if the panels are located on the front or side of the property. This option should be assessed before deciding to use ladders according to the Hierarchy of Control.
- Use tower scaffolding. Tower scaffolding can be used to clean solar panels on the rear or sides of residential properties that a MEWP cannot access.
- Use secured ladders with a fall protection plan. Ladders should only be used as a last resort to access a roof. They should be secured to the building. A fall protection plan should be in place and workers secured to the roof somehow in order to either prevent a fall or ensure that they are not injured in the event of a fall. If this cannot be guaranteed, the clean should not proceed.
One may ask ‘What about the additional cost of a MEWP or scaffolding?’ The additional cost is not discussed or taken into account by the Hierarchy of Risk or OSHA. The cost to be kept safe whilst at work is considered irrelevant. MEWP hire or scaffolding costs are surprisingly understood by residential homeowners when the risks of walking on roofs, insurance liabilities and claims should an accident happen, are explained to them in a clear way. Homeowners generally accept the additional access costs, understanding that you wish to work in a safe manner whilst on their property. If the homeowner does not want to cover the cost to make you safe whilst on their property, do you even want to work for them?
Only after an assessment has been made that the solar panels cannot be cleaned from the ground, by a MEWP or scaffolding, only then should extension ladders be used to physically access the roof. Extension ladders sit right at the bottom of the Hierarchy of Risk. Ladder access to a roof is the most dangerous form of access. Just because ladders are often the quickest and cheapest way to access a roof, does not mean they should be the automatic choice of access. All other access options should have been exhausted before considering ladders.
A different article specifically about using ladders to clean solar panels will eventually be published by ISCA. For now, there is extensive OSHA guidance on ladders here: https://www.osha.gov/sites/default/files/publications/osha3124.pdf
However, it is essential to know in the case of solar panel cleaning, the following:
- Only ladders with non-conductive siderails should be used to access roofs where there are solar panels. The risk of electrocution exists from the solar panels and the worker and ladders are exposed to that risk, should they come into contact with the solar array.
- Ladders should be extended more than 3 feet (0.9m) above the access level to allow for vertical or horizontal grab bars.
- Ladders should be fixed and secured at all times when in use.
Step Three: What Administrative Controls Can Reduce Risk?
Administrative controls are those policies made by you or your company to keep you safe whilst at work. Specific to solar panel cleaning, these would include solar panel cleaning safety awareness training, working at height training and procedures, safe work practices, emergency rescue procedures, controlling access zones so that pedestrians cannot enter your workspace, etc.
Step Four: What Personal Protective Equipment (PPE) Should Be Worn?
There are numerous forms of PPE needed in order to safely clean solar panels. In this article, we will only discuss those relevant to working at height on residential properties.
Guard rails, travel restraints and safety nets will not be present on a residential property. Therefore, everything revolves around a robust fall protection system. Fall protection systems firstly try to prevent a fall from occurring. Should a fall occur, the fall protection plan will ensure that a worker does not hit the ground or level below. They catch the worker in the event of a fall. Fall protection systems should be carefully planned, designed and installed so that they do not allow a worker to fall and ‘bottom out’ or be injured in the fall.
Fall protection plans are made up of two components, theory and practical. Firstly, there should be a written fall protection plan in place to explain how you intend to access and work safely on a roof. This will include route and hose planning to ensure no slip or trip can occur. Consideration should also be given to ensure the worker is not working on wet tiles. This can often be achieved by cleaning the solar panels from above.
Secondly, you should have the correct training and equipment needed to execute your plan. Training may come in the form of rope and/or harness training. Equipment will include rope and/or harnesses and lanyards and a hard hat with chinstrap. A chinstrap is essential when working at height, to prevent the hat coming off your head in the event of a fall.
Conclusion – Residential Solar Panel Cleaning Access Takeaway Points
- Falling from height whilst solar panel cleaning is a frequent and potentially fatal risk
- OSHA and other coutnry-specific heath and safety guidance should be followed by all, including sole traders and these always require industry-specific training
- Consider the Hierarchy of Control
- Create a written Fall Protection Plan and follow it
- Remember, ladders should only be used to access a roof as a last resort, irrespective of cost