Wayne's Roofing, Inc., V. Wa Department Of Labor & Industries

CourtCourt of Appeals of Washington
DecidedFebruary 9, 2026
Docket87182-0
StatusUnpublished

This text of Wayne's Roofing, Inc., V. Wa Department Of Labor & Industries (Wayne's Roofing, Inc., V. Wa Department Of Labor & Industries) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wayne's Roofing, Inc., V. Wa Department Of Labor & Industries, (Wash. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE

WAYNE’S ROOFING, INC., No. 87182-0-I

Respondent,

v. UNPUBLISHED OPINION WASHINGTON STATE DEPARTMENT OF LABOR AND INDUSTRIES,

Appellant.

BOWMAN, A.C.J. — In August 2021, Wayne’s Roofing Inc. employee

William Knight was inspecting a portion of a 12-foot, 1-inch-high roof at Kentridge

High School without using a fall protection system. The Department of Labor and

Industries (L&I) cited Wayne’s Roofing for failing to use a fall protection system

on a low-pitched roof and imposed a $43,200 penalty. Wayne’s Roofing

appealed to the Board of Industrial Insurance Appeals (Board), which affirmed

the citation. Wayne’s Roofing then appealed to the King County Superior Court,

which concluded that Knight’s inspection activities rendered him exempt from

using fall protection and reversed L&I’s citation. L&I appeals. Because

construction work was underway on the roof that Knight was inspecting, WAC

296-880-30005(3)(b)’s exemption to using a fall protection system does not

apply. We reverse the superior court and affirm the Board’s decision. No. 87182-0-I/2

FACTS

In July 2021, Wayne’s Roofing began a project at Kentridge High School

in Kent. The project involved replacing roofing over four acres of buildings and

walkways.

On August 3, 2021, Knight, a foreperson for Wayne’s Roofing, stood on a

10-foot-wide by 100-foot-long flat, unguarded roof area that was 12 feet, 1 inch

off the ground. He used no fall protection system and was looking for anchor

points on the roof to install fall protection equipment for his crew. Knight was five

to eight steps from a part of the roof where construction work had begun.

Meanwhile, compliance safety and health officer (CSHO) Patrick Oliver

drove by the site and saw Knight on the roof without fall protection. Oliver took a

photograph of Knight, as shown below, while he inspected the jobsite.

On September 17, 2021, L&I cited Wayne’s Roofing for a “Repeat

Serious” violation of WAC 296-880-30005(1)(a)1 and imposed a $43,200 penalty.

1 L&I had cited Wayne’s Roofing for the same violation on February 19, 2019,

May 17, 2019, and October 7, 2020.

2 No. 87182-0-I/3

The citation stated, “Upon inspection, the CSHO observed [one] employee

exposed to a fall hazard of [12] feet, [1] inch while conducting roofing work on the

edge of a roof, without the use of an appropriate fall protection system.”

Wayne’s Roofing appealed the citation and L&I held a hearing. On

November 9, 2021, L&I issued a “Corrective Notice of Redetermination” (CNR),

affirming the citation and penalty assessment. On November 22, 2021, Wayne’s

Roofing appealed the CNR to the Board.

In November 2022, an industrial appeals judge (IAJ) held a hearing. The

parties stipulated that Knight was engaged in roofing work without fall protection

on a roof more than 12 feet high. Wayne’s Roofing argued, among other things,

that WAC 296-880-30005(3)(b)’s exemption to the fall protection regulation

applies because Knight was inspecting roof conditions before construction began

on that section of the roof.

L&I presented testimony from CSHO Oliver that the exemption does not

apply because construction work had started. And it presented testimony from

Erich Smith, an L&I safety technical specialist responsible for interpreting and

applying certain WACs concerning fall protection. Smith testified that while there

was no construction work underway on the “specific section of the roof” where

Knight stood, that fact has no bearing on whether the exemption applies because

construction work had begun on another section of the roof.

On March 7, 2023, the IAJ entered a proposed decision and order,

concluding that Wayne’s Roofing “committed a repeat serious violation of WAC

296-880-30005(1)(a)” and that L&I “appropriately assessed a $43,200 penalty.”

3 No. 87182-0-I/4

The IAJ found that “construction work had started [five to eight] steps from where

Mr. Knight stood on the unguarded roof without fall protection.” And Knight “was

inspecting, investigating, or assessing roof-level conditions on a low-pitched roof

after the start of construction work.” It also found that Wayne’s Roofing failed to

prove that the WAC 296-880-30005(3)(b) exemption applies because

“construction had started just a few steps from where Mr. Knight was

photographed without fall protection.”

On April 25, 2023, Wayne’s Roofing petitioned the Board for review, again

arguing that Knight was exempt from having to use fall protection under WAC

296-880-30005(3)(b). The Board denied the petition for review and adopted the

IAJ’s proposed decision and order as its “Decision and Order.”

On June 6, 2023, Wayne’s Roofing appealed to the King County Superior

Court. After a hearing, the superior court entered findings of fact and

conclusions of law. The court reversed L&I’s citation, concluding that Knight’s

conduct was exempt under WAC 296-880-30005(3)(b) because the regulation

“applies not solely to the start of the entire construction project but to the start of

construction work upon a designated section of the larger project.”

L&I appeals.

ANALYSIS

L&I argues the superior court erred by reversing the Board because

substantial evidence supports the Board’s decision that Wayne’s Roofing violated

WAC 296-880-30005(1)(a). Wayne’s Roofing argues that the Board erred

4 No. 87182-0-I/5

because Knight was exempt from the fall protection regulation under WAC 296-

880-30005(3)(b). We agree with L&I.

The Washington Industrial Safety and Health Act of 1973 (WISHA),

chapter 49.17 RCW, governs judicial review of decisions that the Board issues.

Erection Co. v. Dep’t of Lab. & Indus., 160 Wn. App. 194, 201, 248 P.3d 1085

(2011). In a WISHA appeal, we review a decision based on the record before the

Board, not the superior court. Ostrom Mushroom Farm Co. v. Dep’t of Lab. &

Indus., 13 Wn. App. 2d 262, 271, 463 P.3d 149 (2020). We determine whether

substantial evidence supports the Board’s findings of fact and, if so, whether

those findings support the Board’s conclusions of law. J.E. Dunn Nw., Inc. v.

Dep’t of Lab. & Indus., 139 Wn. App. 35, 42, 156 P.3d 250 (2007). The Board’s

findings of fact are conclusive if substantial evidence supports them. Frank

Coluccio Constr. Co. v. Dep’t of Lab. & Indus., 181 Wn. App. 25, 35, 329 P.3d 91

(2014). Substantial evidence is evidence sufficient “to persuade a fair-minded

person of the truth of the declared premise.” Id. We view the evidence and all

reasonable inferences drawn from it in favor of the party that prevailed in front of

the Board. Ostrom, 13 Wn. App. 2d at 271. Unchallenged findings are verities

on appeal. Frank Coluccio, 181 Wn. App. at 35.

We review the Board’s interpretation of statutes and regulations de novo

but “give substantial weight to an agency’s interpretation of a regulation within its

area of expertise.” Erection Co., 160 Wn. App. at 201-02. We interpret WISHA

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Related

JE Dunn Northwest, Inc. v. DEPT. OF LABOR & INDUSTRIES
156 P.3d 250 (Court of Appeals of Washington, 2007)
Erection Co. v. DEPT. OF LABOR & INDUSTRIES
248 P.3d 1085 (Court of Appeals of Washington, 2011)
Washington Cedar & Supply Co. v. State
154 P.3d 287 (Court of Appeals of Washington, 2007)
Washington Cedar & Supply Co. v. Department of Labor & Industries
137 Wash. App. 592 (Court of Appeals of Washington, 2007)
J.E. Dunn Northwest, Inc. v. Department of Labor & Industries
139 Wash. App. 35 (Court of Appeals of Washington, 2007)
Erection Co. v. Department of Labor & Industries
160 Wash. App. 194 (Court of Appeals of Washington, 2011)
Frank Coluccio Construction Co. v. Department of Labor & Industries
329 P.3d 91 (Court of Appeals of Washington, 2014)

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