PPE Requirements for Roofing Work

When a personal fall arrest system is the chosen protection method, 1926.502(d) governs the components themselves — harness, connectors, anchorage, and deceleration device all have to meet specific criteria, and the system has to be rigged so a worker can neither free-fall more than a limited distance nor contact a lower level. Buying a harness off the shelf isn't the same as having a compliant, correctly rigged system for the specific roof it's being used on.

General construction PPE requirements live in 29 CFR 1926 Subpart E, and within that, eye and face protection (1926.102) logged 1,665 violations nationally in OSHA's FY2025 Top 10 — with roofing contractors leading that category, most often for providing no eye or face protection at all rather than for using non-compliant equipment. Nail guns, saws, grinders, and debris kicked up during tear-off are routine roofing-jobsite conditions that trigger this requirement, and it's the PPE item crews most often skip.

A PPE program that holds up starts with a documented hazard assessment specific to the actual work being done — tear-off, hot work, fastening, material handling — rather than a generic "hard hat and boots" checklist copied from another trade. The assessment should identify what hazard each PPE item is addressing, who's responsible for providing and maintaining it, and how training on correct use gets documented so it's demonstrable, not just assumed.