Each year, construction and maintenance workers suffer serious injuries from falls through unprotected skylights on seemingly “finished” roofs. These preventable incidents highlight a critical question: If a skylight is made of sturdy glazing or domed acrylic, does it still count as a hole under OSHA? Let’s break down OSHA’s language, real-world enforcement, and practical steps for contractors, designers, and building owners to stay compliant and keep workers safe.
OSHA 1910.28 and Skylights
OSHA’s fall protection standard, 29 CFR 1910.28(b)(3)(i), defines a “hole” as any gap or open space in a roof or floor where an employee could fall through to a lower level. The rule explicitly states: “Each employee is protected from falling through any hole (including skylights) that is 4 feet or more above a lower level by one or more of the following: covers, guardrail systems, travel restraint systems, or personal fall arrest systems.” OSHA considers skylights “holes” unless they are specifically designed and tested to withstand a fall without breaking. Even domed, “walkable,” or reinforced skylights often fail to meet OSHA’s stringent criteria for being “guarded” because their glazing may not withstand a worker’s weight or impact during a fall.
What Counts as “Guarded” in OSHA’s Eyes?
To comply with OSHA, skylights must be protected by one of these methods:
- Skylight safety screens: Must support at least 200 pounds of force (or twice the weight of the heaviest worker and equipment) without failure.
- Guardrail systems: Must surround the skylight and meet OSHA’s height and strength requirements (e.g., 42 inches tall, able to withstand 200 pounds of lateral force).
- Personal fall arrest systems: Harnesses and anchor points used during work near skylights.
What doesn’t qualify? Plastic glazing, even if impact-rated, rarely meets OSHA’s fall protection standards. Decorative grates or untested covers also fall short unless certified for fall loads.
Common Myths and Misconceptions
Misunderstandings about skylights can lead to costly violations or tragic accidents. Here are three common myths debunked:
- “If it’s rated for impact, it’s safe.” Not true. Impact resistance (e.g., for hail) doesn’t guarantee the skylight can support a worker’s weight or prevent a fall-through. OSHA requires specific fall protection testing.
- “It’s flush with the roof — no one will trip or fall through.” Falls through skylights are often vertical, caused by stepping directly onto weak glazing, not tripping.
- “We only need protection during construction.” Skylights pose risks for years, especially for maintenance crews accessing roofs for HVAC, solar, or cleaning tasks.
Real-World Citations and Case Examples
OSHA citations for skylight-related violations are common. In 2017, California OSHA (Cal/OSHA) issued $80,620 in penalties to the company for exposing workers to fall hazards at a job site in Novato, California. The violations included failing to install barriers near skylights and leaving floor openings unprotected, which led to a worker suffering serious injuries after falling 23 feet through a skylight. No fatalities were reported in this incident.
Lessons learned:
- Implement Robust Fall Protection Systems: Ensure skylights and roof openings are secured with safety screen, guardrails, or other barriers compliant with OSHA standards to prevent falls, as the lack of such measures directly contributed to the worker’s injury.
- Conduct Regular Safety Training: Train workers on recognizing and mitigating fall hazards, including proper use of personal protective equipment (PPE) and safe work practices around skylights, to reduce the risk of accidents.
- Perform Proactive Site Inspections: Regularly inspect job sites to identify and address potential hazards, such as unprotected skylights, before work begins, to avoid costly violations and ensure compliance with safety regulations.
Conclusion: Are Skylights Holes?
If it’s a skylight and someone could fall through it, it’s considered a hole. The safest, simplest path to compliance is to plan early, specify clearly, and verify that fall protection is both present and properly installed. Products like the R&S’ OSHA-compliant SafeScreen for LTP’s and SafeScreen for roof curbs provide a durable, cost-effective solution that can be installed over and under skylights and to bring your project into compliance without compromising light or roof integrity.
