Taking Precautions
Preventing Skylight Falls with an Updated Safety Standard
by Glenn Ferris, FGIA Fenestration Standards Specialist
Skylights make for an interesting feature to a building, while also allowing for natural daylight and many other benefits. But an asset like a skylight unit can come with some risk. That is why the Fenestration and Glazing Industry Alliance (FGIA) is in the process of revising its skylight fall protection and awareness guidelines to help ensure safety around these kinds of products.
For a number of years, the United States Occupational Safety and Health Administration (OSHA), and similar authorities, have established regulations to address the testing of skylights for their ability to withstand an impact from a falling human. However, OSHA’s criteria lack clarifying language, and there is currently no single standardized method for testing a skylight’s ability to withstand a human falling through one. California, for example, has not updated its Cal/OSHA requirements to reflect the last, 2017 revisions.
The lack of a well-defined load and impact rating leaves compliance open to considerable interpretation, which can cause a catch-22. The building owner and contractor look to the skylight and/or protective screen manufacturer for aid, but they, in turn, look to the building owner and contractor for their specifications. Of course, nobody wants to make the assumptions required, thus absorbing potential liability.
There are critical questions that should not be left open, such as how a test load should be applied, and what area it should cover. FGIA’s Skylight and Sloped Glazing Council has been working diligently along with other concerned individuals and safety organizations to develop a new ASTM standard: WK17797 “New Test Method for Standard Specification for Human Impact and Fall-through Resistance of Unit Skylights and Related Products Used on Skylight Openings on Commercial Buildings.”
Much of the interpretation issue stems from language OSHA revised in 2017 regarding the regulation of protective screen covers over skylights and their testing. The updated OSHA language allowed more flexibility for building owners and contractors to comply, but it also increased confusion on demonstrating compliance. This is largely due to the removal of language that once stated, as per 29 CFR 1910.23 (a)(4):
“Skylight screens shall be of such construction and mounting that they are capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen. They shall also be of such construction and mounting that under ordinary loads or impacts, they will not deflect downward sufficiently to break the glass below them. The construction shall be of grillwork with openings not more than four inches long or of slat work with openings not more than two inches wide with length unrestricted.”
While FGIA hailed the edit at the time, its removal and a lack of new clarifying language created more problems. The Association’s membership has long believed that the 200-pound load test is not sufficient, nor is the description of how the load is applied. Relatively weak screen products that meet OSHA’s fall protection requirements, have been shown to only pass this requirement when the sandbags, used to represent a falling body, are carefully stacked to apply the load. The Association, however, believes the load requirement should be a dynamic drop test, to more closely replicate the impact forces of a falling worker.
Another matter that FGIA has challenged is the OSHA language requiring skylight glazing from breakage since the goal of the safety screen is not to protect the product, but the worker from falling through the skylight opening. Factually, a skylight itself is often stronger than the screen that is required to be installed over it. Furthermore, the OSHA language does not clearly state if the skylight itself, can act as the cover for the skylight.
To summarize, the 2017 criteria for protecting a skylight’s opening, essentially reverted to the general requirements of all covers for roof and floor openings, including skylight openings. Due to this lack of a standard for testing covers, members of the FGIA Skylight and Sloped Glazing Council has developed the fall protection and awareness guidelines. It is anticipated to be published in the coming months.
