Reglets AHA (Activity Hazard Analysis / Job Hazard Analysis)

Updated 2026-06-23

A Reglets AHA (Activity Hazard Analysis / Job Hazard Analysis) is the plan that keeps the crew installing reglets safe from the masonry cutting silica dust, from the at-height wall and roof-edge fall, and around the sharp metal- edge and fastening. Reglets installs reglets for counterflashing — combining the masonry-cutting-silica-dust hazard, the at-height-wall and roof-edge-fall hazard, and the sharp-metal-edge and fastening hazard. This guide walks through building a Reglets AHA that names the masonry-cutting-silica-dust, at-height-wall/roof-edge-fall, and sharp-metal-edge/fastening hazards and assigns the silica-dust, fall, and cut/fastening controls that hold up in the field.

Why reglets needs its own AHA

Reglets is the installation of reglets for counterflashing — the reglets (the grooves cut or formed into masonry/ concrete walls, and the sheet-metal reglet pieces set into them, to receive and secure counterflashing at roof-to- wall transitions). This closes the specialties group and the batch. The defining feature that distinguishes reglets from the other sheet-metal specialties is the masonry cutting: cutting a reglet groove into a masonry or concrete wall (with a grinder or masonry saw) generates crystalline silica dust — a serious respiratory hazard — which is the signature reglet hazard, on top of the at-height wall/roof-edge work and the sharp metal reglet/flashing edges. The hazards combine the masonry-cutting-silica-dust (cutting the reglet groove into masonry — the silica-dust hazard), the at-height-wall and roof-edge-fall (working at the wall/roof-edge transition — the fall hazard), the sharp-metal-edge and fastening (the sharp metal reglet/flashing edges and fastening — the cut and fastening hazards), and the eye. The masonry-cutting-silica-dust and the at-height-wall/roof-edge-fall justify a dedicated AHA.

Breaking reglets into steps

The steps for a Reglets AHA follow the work:

  • Set up silica dust controls (cutting method, respiratory)
  • Set up wall/roof-edge fall protection
  • Cut the reglet groove into the masonry (silica dust)
  • Set and fasten the reglet
  • Install the counterflashing into the reglet
  • Manage the silica, fall, and cut hazards
  • Complete

Each step carries a hazard, and the masonry-cutting-silica-dust, the at-height-wall/roof-edge-fall, and the sharp- metal-edge/fastening are where the most significant risks concentrate.

The hazards step by step

Masonry-cutting-silica-dust

Cutting the reglet groove into masonry — the silica-dust hazard. The controls are silica-dust controls (cutting a reglet groove into a masonry or concrete wall with a grinder or masonry saw generates respirable crystalline silica dust (masonry and concrete are silica-containing — a serious respiratory hazard, silicosis and other silica diseases), so the silica controls per the respirable-crystalline-silica requirements: dust controls on the cutting tool (a grinder/saw with a dust shroud and vacuum dust collection, or wet cutting), respiratory protection appropriate to silica, and following an exposure-control plan), and the silica-dust controls. The masonry-cutting- silica-dust is the primary defining hazard — cutting the reglet groove into masonry is a silica-dust hazard. (These follow the silica fundamentals.)

At-height-wall and roof-edge-fall

Working at the wall/roof-edge transition — the fall hazard. The controls are wall/roof-edge fall protection (reglets are cut and installed at roof-to-wall transitions — at the wall above the roof edge/parapet, at height — so fall protection at the roof edge and for the wall work (personal fall arrest, guardrails as applicable), and safe access (ladders/scaffolds/lifts), recognizing the reglet work is at the roof-edge/parapet transition), and the fall controls. The at-height-wall/roof-edge-fall is a defining hazard — reglet work is at the roof-to-wall transition at height. (These follow the fall-protection fundamentals.)

Sharp-metal-edge and fastening

The sharp metal reglet/flashing edges and fastening — the cut and fastening hazards. The controls are sharp-metal- edge and fastening controls (the sheet-metal reglet pieces and the counterflashing have sharp cut edges (a laceration hazard — cut-resistant gloves and careful handling), and fastening the reglet into the masonry (fastening tools, masonry fasteners — the fastening-tool hazards) and sealing it (sealant-chemical)), and the cut/ fastening controls. The sharp-metal-edge/fastening is a defining hazard — the metal reglet and flashing have sharp edges. (These follow the sharp-edge and fastening fundamentals.)

Eye

The eye (silica dust, cutting, fastening) carries the eye hazard. The controls are eye protection (masonry-cutting silica dust, metal cutting, and fastening debris — full eye protection given the masonry cutting), and the eye controls. (These follow the eye-protection fundamentals.)

A simple Reglets AHA structure

StepHazardControlStandard
Silica controlsSilicaSet up silica dust controls (cutting method, respiratory)OSHA 1926.1153
Fall protectionFallSet up wall/roof-edge fall protectionOSHA 1926.501
Cut grooveSilicaCut the reglet groove into the masonry (silica dust)OSHA 1926.1153
Set regletSharp edge / fasteningSet and fasten the regletOSHA 1926.302
CounterflashingSharp edgeInstall the counterflashing into the regletproject
ManageSilica / fallManage the silica, fall, and cut hazardsproject

Masonry-cutting silica-dust control and wall/roof-edge fall protection

A Reglets AHA centers on masonry-cutting silica-dust control and wall/roof-edge fall protection. The masonry- cutting silica-dust control addresses the reglet-groove cutting — controlled by silica-dust controls (dust shroud and vacuum or wet cutting, respiratory protection, exposure-control plan). The wall/roof-edge fall protection addresses the transition work — controlled by wall/roof-edge fall protection (fall protection, safe access). And the sharp metal edges, fastening, and eye get cut/fastening and eye controls. An AHA built on masonry-cutting silica-dust control and wall/roof-edge fall protection, with cut/fastening controls, addresses the hazards that define reglets.

From the field: what actually goes wrong

In fourteen years across federal, heavy civil, and industrial projects, reglets installs the grooves cut into masonry/concrete walls (and the sheet-metal reglet pieces set into them) that receive and secure counterflashing at roof-to-wall transitions, and it closes the specialties group and this batch with a hazard that sets it apart from the other sheet-metal specialties: the masonry cutting. The masonry-cutting-silica-dust hazard is the primary defining concern — cutting a reglet groove into a masonry or concrete wall with a grinder or masonry saw generates respirable crystalline silica dust (masonry and concrete are silica-containing — a serious respiratory hazard, silicosis and other silica-related diseases), so the silica controls per the respirable-crystalline-silica requirements are essential: dust controls on the cutting tool (a grinder or saw fitted with a dust shroud and vacuum dust collection, or wet cutting), respiratory protection appropriate to the silica exposure, and following an exposure-control plan. The silica dust from cutting the groove into masonry is the defining hazard, and it is the reason reglet work needs the silica discipline that the other sheet-metal specialty work does not.

The at-height-wall/roof-edge-fall and the sharp-metal-edge/fastening are the other defining hazards. On the projects I have run, reglets are cut and installed at roof-to-wall transitions — at the wall above the roof edge or parapet, at height — so fall protection at the roof edge and for the wall work (personal fall arrest, guardrails as applicable) and safe access (ladders, scaffolds, or lifts) matter, recognizing the reglet work is at the roof-edge/ parapet transition. And the sharp-metal-edge/fastening hazard is that the sheet-metal reglet pieces and the counterflashing have sharp cut edges (a laceration hazard — cut-resistant gloves and careful handling), fastening the reglet into the masonry (fastening tools, masonry fasteners), and sealing it (sealant-chemical). The eye hazard from the masonry-cutting silica dust rounds it out. This closes the specialties group and the batch. The AHA built on masonry-cutting silica-dust control and wall/roof-edge fall protection is the one that protects the reglet crew.

The bottom line

A Reglets AHA names the masonry-cutting-silica-dust, the at-height-wall/roof-edge-fall, and the sharp-metal-edge/ fastening hazards with specific controls — silica-dust controls (dust shroud and vacuum or wet cutting, respiratory protection, exposure-control plan for the reglet-groove cutting), wall/roof-edge fall protection (fall protection, safe access), and sharp-metal-edge and fastening controls (cut-resistant gloves for the sharp reglet/flashing edges, safe fastening and sealing). The masonry-cutting silica-dust control and the wall/roof-edge fall protection are the defining concerns. The AHA that manages both is the one that protects the crew.

Frequently asked questions

Why is cutting the reglet groove a silica-dust hazard?

Cutting a reglet groove into a masonry or concrete wall with a grinder or masonry saw generates respirable crystalline silica dust (masonry and concrete are silica-containing — a serious respiratory hazard, silicosis and other silica diseases). Controls are silica-dust controls (dust controls on the cutting tool — a grinder/saw with a dust shroud and vacuum dust collection, or wet cutting; respiratory protection appropriate to silica; following an exposure-control plan per the respirable-crystalline-silica requirements), and the silica-dust controls.

What fall hazards apply?

Reglets are cut and installed at roof-to-wall transitions — at the wall above the roof edge/parapet, at height. Controls are wall/roof-edge fall protection (fall protection at the roof edge and for the wall work — personal fall arrest, guardrails as applicable; safe access — ladders/scaffolds/lifts), and the fall controls.

What sharp-edge and fastening hazards apply?

The sheet-metal reglet pieces and the counterflashing have sharp cut edges (a laceration hazard), fastening the reglet into the masonry (fastening tools, masonry fasteners), and sealing it (sealant-chemical). Controls are sharp-metal-edge and fastening controls (cut-resistant gloves and careful handling, safe fastening, sealant-chemical safety), and the cut/fastening controls.

What is reglets?

Reglets is the installation of reglets for counterflashing — the reglets (the grooves cut or formed into masonry/concrete walls, and the sheet-metal reglet pieces set into them, to receive and secure counterflashing at roof-to-wall transitions). Because cutting the reglet groove into masonry generates silica dust, the work is at the roof-to-wall transition at height (fall), and the metal reglet/flashing has sharp edges, those hazards apply.


Written by Mustafa Tok, CSP, ASP, CHST — OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.