{"id":1452,"date":"2022-10-30T09:22:19","date_gmt":"2022-10-30T09:22:19","guid":{"rendered":"https:\/\/theisca.org\/?p=1452"},"modified":"2022-11-23T10:43:05","modified_gmt":"2022-11-23T10:43:05","slug":"residential-solar-panel-cleaning-working-at-height-guidance-part-2","status":"publish","type":"post","link":"https:\/\/theisca.org\/index.php\/2022\/10\/30\/residential-solar-panel-cleaning-working-at-height-guidance-part-2\/","title":{"rendered":"Residential Solar Panel Cleaning Working At Height Guidance – Part 2"},"content":{"rendered":"

Part 1<\/strong><\/a> 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.\u00a0 The guidance is broken down into 4 steps, the first of which is in Part 1:\u00a0 Eliminate the Need For Working At Height Where Possible and why cleaning from ground level should be the go-to option on all jobs.\u00a0 For reference during this article, here is the Hierarchy of Fall Protection again:<\/p>\n

\"Hierarchy

The Hierarchy of Fall Protection should be considered for commercial and residential jobs<\/p><\/div>\n

Part 2 will now discuss how solar panel cleaning can be done safely if working from ground level is not possible.<\/p>\n

Step Two:\u00a0 What Engineering Controls Can Be Used To Reduce Works at Heights?<\/strong><\/h2>\n

Engineering controls are those that are built into the design of the building, equipment, materials or other aspects of the work environment.\u00a0 These can take the shape of fixed or stationary guardrails.\u00a0 These are preferable as they do not rely on a worker being trained and using a harness or other form of fall protection.<\/p>\n

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).<\/p>\n

Engineering controls should be used wherever possible.\u00a0 However, guardrails and rooflight covers will not be installed on homes.\u00a0 However, fall protection techniques for solar panel cleaning on residential properties are available and should always be used.<\/p>\n

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.<\/strong><\/p>\n

Where residential solar panels cannot be reached from ground level what options should be considered?<\/p>\n

    \n
  1. Use an A-frame ladder.<\/strong> 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. \u00a0Providing the height worker on the ladder is no more than 4 feet<\/strong>, this is a safe working method.<\/li>\n
  2. Use a MEWP.<\/strong> Cleaning solar panels from a MEWP is often possible if the panels are located on the front or side of the property.\u00a0 This option should be assessed before deciding to use ladders according to the Hierarchy of Control.<\/li>\n
  3. Use tower scaffolding.<\/strong> Tower scaffolding can be used to clean solar panels on the rear or sides of residential properties that a MEWP cannot access.<\/li>\n
  4. Use secured ladders with a fall protection plan. <\/strong>Ladders should only be used as a last resort to access a roof.\u00a0 They should be secured to the building.\u00a0 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.\u00a0 If this cannot be guaranteed, the clean should not proceed.<\/li>\n<\/ol>\n

    One may ask \u2018What about the additional cost of a MEWP or scaffolding?\u2019\u00a0 The additional cost is not discussed or taken into account by the Hierarchy of Risk or OSHA. \u00a0The cost to be kept safe whilst at work is considered irrelevant.\u00a0 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.\u00a0 Homeowners generally accept the additional access costs, understanding that you wish to work in a safe manner whilst on their property. \u00a0If 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?<\/p>\n

    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.\u00a0 Extension ladders sit right at the bottom of the Hierarchy of Risk.\u00a0 Ladder access to a roof is the most dangerous form of access.\u00a0 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.\u00a0 All other access options should have been exhausted before considering ladders.<\/strong><\/p>\n

    A different article specifically about using ladders to clean solar panels will eventually be published by ISCA.\u00a0 For now, there is extensive OSHA guidance on ladders here:\u00a0 https:\/\/www.osha.gov\/sites\/default\/files\/publications\/osha3124.pdf<\/a><\/p>\n

    However, it is essential to know in the case of solar panel cleaning, the following:<\/p>\n