Five-page review by Sunoptics executive Grant Grable that walks through OSHA 1926 (construction) and 1910 (occupied buildings) skylight rules and argues that an unscreened plastic dome, however strong when new, is not lifetime fall protection.
Overview
This five-page white paper, written by Grant Grable of prismatic-skylight maker Sunoptics, takes on a marketing claim that circulates in the roofing trade: that a plastic skylight dome can itself be "OSHA compliant." Grable reprints the federal rules that govern skylight openings, splits them into the two regimes that actually apply (construction sites versus finished buildings), and then asks whether a dome that passes a load test on the day it is installed still protects a worker ten or twenty years later. His answer is no, and his remedy is a permanently installed screen inside the curb.
Key Findings
- OSHA does not approve, certify or endorse products of any kind. A manufacturer's "OSHA compliant" label is the manufacturer's own claim, and Grable calls the confusion between "compliant" and "approved" the single biggest misconception about skylights in the roofing community.
- Two separate rule sets apply. Part 1926 (construction) covers the opening only while the roof is being built or replaced; Part 1910 (general industry) covers the finished building for its entire life. Manufacturers who cite 1926 are, in his view, citing the wrong rule for an installed skylight.
- The construction rules he quotes require a cover able to hold a 200-pound person (1926.500) and, elsewhere, one able to carry at least twice the weight of workers, tools and materials that could land on it at once (1926.502(i)(2)). Neither text mentions product lifespan or UV aging.
- The general-industry rule he quotes (1910.23) calls for a standard skylight screen or railing on every skylight opening, with the screen able to take a 200-pound perpendicular load anywhere on its surface, built as grillwork with openings no more than 4 inches or slats no wider than 2 inches, and stiff enough not to break the glazing below it.
- All plastics lose strength under sun exposure, and dome thickness and formulation vary widely between makers. He also raises point loading: a roofer tripping onto a dome with a powered screw gun concentrates his weight on a bit tip smaller than 1/16 inch, a load no plastic formulation can be expected to survive.
- Exterior-mounted guards create a compliance gap at reroof time, because the dome and guard come off for flashing work and the opening usually ends up covered with a sheet of plywood. A curb-top screen of 4-inch grillwork mounted inside the skylight stays in place through reroofing and, he states, satisfies both federal OSHA and the then-new Cal/OSHA skylight rules.
Why It Matters for Daylighting
For warehouse, distribution and manufacturing owners, this piece names the hazard that follows every toplighting decision: a roof full of skylights is a roof full of holes that look like solid surface. The practical takeaway, that fall protection should be a permanent part of the skylight assembly rather than a removable exterior cage, is now common practice across the prismatic-skylight trade. Logistics Lighting supplies that protection alongside the skylight, either as a safety screen pre-installed in the roof curb or as a separate external fall-protection screen sized to the opening.
One important update: the 1910.23 text Grable quotes was rewritten in OSHA's 2017 Walking-Working Surfaces rule. The skylight duty now lives in 1910.28(b)(3), and the screen and cover criteria in 1910.29(e), where the 200-pound screen test was replaced by a "twice the maximum intended load" requirement. The logic of the article survives that change intact; the citations do not, so check current text before quoting.
About the Source
Author Grant Grable, LEED AP, is a long-time Sunoptics (Acuity Brands) executive and a frequent speaker and writer on daylighting and roofing. No magazine or website publication of this paper could be located; the document has no masthead, and its file name ("OSHA Fall Protection Review V1") suggests a manufacturer white paper circulated to roofing contractors. Five pages, undated, with two photographs comparing new and aged domes. Readers wanting the primary text should go straight to OSHA's 1910.28 and 1926.501 standards.
This page is an original summary written by Logistics Lighting. The source article is the copyrighted work of its publisher and is referenced here for research and educational purposes under the fair-use provisions of Section 107 of the U.S. Copyright Act. A reference copy of the original is provided for convenience; please contact the publisher for any use beyond fair use.
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