Fall Protection

OSHA Update: Walking Working Surface Regulations

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Earlier this year, OSHA made headlines for the way it would revise the regulations regarding fall protection for general industry.

Did you know about the change?

As explained by the department itself, the modification accounts for modernization of technology along with updates to old regulations.

It’s important that building owners and managers understand the new developments. If you don’t, you could be facing fines from the government – or worse, accidents at your property with increased legal liability. 

There are several subtle changes in the regulations that have large implications.  Specifically, the changes in fall protection for facade access and building maintenance could potentially be costly for building owners.

Here’s what you need to know.

Standards for Window Washing & Exterior Maintenance

You’re probably aware of the complicated protocol that already exists around suspended scaffolding systems.

Now, a few new rules have been tossed into the mix for General Industry. OSHA has basically adopted various ANSI, ASME, and IWCA standards that were loosely followed in the past.  These are now law with clearly defined minimum requirements. 

The most important example is the minimum load any rope descent (i.e. boatswain or bosun’s chair) anchorage must now support. Prior to this update, a minimum of two to one safety factor was allowed (typically resulting in an anchor that could support around 1800 pounds). Now, ALL anchorages must be able to hold 5,000 pounds minimum.

Height standards are also changing for rope descent systems. No rope descent system can be anchored 300 feet above the base of a building barring some sort of extraordinary circumstance. Owners of buildings above this threshold will now have to accommodate the switch to powered platforms for window washing.

The ANSI/IWCA I-14 standard was widely considered the industry standard regarding anchorage testing and inspection. OSHA has now adopted the intent of this standard into the 1910.27 regulation. Building owners are now required to have their roof anchorages load tested upon installation, inspected annually, and load tested again every ten years.

The key takeaway from these changes is that OSHA is shifting much of the safety burden onto building owners and away from contractors.  Building owners are now REQUIRED to provide and have written certification that their anchorages meet the new standards.  Gone are the days where contractors could provide temporary anchorages to aid in window washing and exterior maintenance. 

Deadlines for Implementation

The new regulations for rope descent can be costly as mentioned, but OSHA is not allowing much time for building owners to get up to speed. There are no “grandfather” type exceptions in the regulation, just a set deadline of November 20, 2017 to comply.

What does it mean if your building is not ready by then?

To put it simply, you will not be allowed to legally wash your windows or undergo exterior maintenance work until it is. There are options such as boom lifts for lucky building owners that have properties accessible from the ground, but any type of rope descent access that requires overhead suspension is not allowed.

Penalties for Accidents

There are no new fines that have been introduced as part of this new OSHA regulation overhaul. Keep in mind though that OSHA already approximately doubled fines towards the end of 2015.   

Fines however, could be the least of one’s worries. As most building owners already know, potential legal damages in the event of a serious accident would far exceed any fines OSHA could levy. Throw a non-compliant building into the case, and the liability skyrockets. 

A Good Thing?

Those who will face the immediate brunt of these costs will certainly disagree that this is good change in the short run.  However, the new regulations have many benefits:

  1. Standardization of many loosely followed standards into one clear-cut law;
  2. Increased protection for workers. With permanent exterior maintenance systems now mandated, the potential for falls decreases;
  3. No more guessing – workers now know for certain whether the anchorages their lives depend on are safe for use;
  4. Long term savings in risk premiums as accidents are mitigated.

Regardless if this OSHA update benefits you or not, it is important that you understand it like the back of your hand.

Update Your Facade Access System Now

Dirty windows can make for cranky tenants. The sun’s harmful UV rays continuously pound building exteriors. If you are unable to wash windows or provide exterior maintenance against weathering, your building is in trouble.

The team at DH Glabe & Associates has the expertise to get your building compliant in the most cost-effective manner possible.

Feel free to reach out to someone on our team today to learn how we can help you.

5 Essential Facts About Facade Access Design

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Facade design is an important aspect of any building project, but that doesn’t mean simply considering what the exterior of the finished building will look like.

Facade access design is an essential consideration. A good system will allow for maintenance to take place safely and at a reasonable cost. Maintenance operations can include setting up advertising, cleaning windows, fixing damage and more.

Here are five essential things you need to know about facade access design.

There are temporary solutions…

Temporary solutions for facade access include rope descent systems and hydraulic access platforms.

While these are relatively low-cost solutions, they have their drawbacks too. For example, a hydraulic lift will not reach the highest floors of a tall building, while rope descent work can take quite a long time.

… and permanent solutions

To secure a re-usable solution, a range of systems including monorail cradles or fixed davits might be favored depending on the jurisdiction (California, New York and other states have their own set of specific regulations).

Monorail cradles are useful on large flat or curved surfaces – they travel along a rail at the top of the building and can be lowered to the required level for access to the facade. They may not be appropriate to use for more ‘experimental’ facade designs.

For flat surfaces with less width, a fixed davit may be more cost-effective than a monorail cradle. Fixed davits are single arms which sit in one position and are used to raise and lower a maintenance platform.

Whichever of the two solutions you opt for, permanent or temporary, you will need to ensure that there is also a fall protection system to protect the people who are working on the facade.

Equipment needs to be inspected regularly

Just as facades need to be accessible, so does your facade access system so that it can be inspected and tested for safety at regular intervals.

OSHA 1910.66 states that all permanent equipment used to access a facade must be load tested when installed, and visually inspected every year. Additionally, OSHA 1910.27 states that each anchorages must be inspected annually and re-tested every 10 years.

Novel facade design calls for a novel approach

As modern architects create buildings with new and artistic facades, it’s important to think about how the facade will be accessible for maintenance purposes.

Sometimes, this will require an approach which is slightly different from the norm. This must be considered at an early stage of the project.

If the architect’s vision for facade design would result in a building which causes problems for facade access, there may have to be a compromise – or a novel approach.

It’s always good to get a second opinion

Our facade access design consultancy services allow building owners and architects to take advantage of our expert knowledge to create facade access designs that are safe and cost-effective.

We provide turnkey structural design and engineering solutions for new buildings, and can also help retrofit existing buildings to bring them up to code.  Contact Us today to find out how we can help with your façade access project.

Fall Protection – The Full Package

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It has been said that the best solution for fall protection is to not fall, but as falls account for several deaths on construction sites, it turns out this plan doesn’t work out and will make OSHA very grumpy. This topic may be stale news to the salty veterans who have been around the block a time or two but I would be willing to bet that there are very few who consider all aspects of a fall protection every time they don their harness.

Whether you are the engineer designing the plan or the contractor whose life relies on the plan, there are several aspects of fall protection that need to be considered. The most familiar components of fall protection are the personal fall arrest system and the anchor which the system is attached to. Most anyone who has needed to utilize fall protection in their line of work knows that OSHA requires you to use a personal fall arrest system and be connected to a suitable anchor which is capable of supporting 5,000 pounds or be designed by a qualified person. In addition a fall protection user must consider the anchor location in relation to the work area, the fall distance and a rescue plan which are just as important and easier to overlook.

After determining the personal fall arrest system and a suitable anchor, next, consider the work area in relation to the fall protection anchor: It is always a good practice to keep the fall protection system as close to 90 degrees to the edge of the fall hazard as possible. This will limit the amount of swing in the event of a fall reducing the risk of the worker swinging into an object below.

Next, consider the fall distance to prevent a worker from hitting a lower level or an obstruction below as they fall. This aspect of fall protection has the highest variability and can change with each setup. The fall distance can be as little as a few feet if using a self-retracting lifeline attached to a rigid anchor to upwards of 20 feet with some horizontal lifeline applications.

Finally, any fall protection plan is pointless without a way to rescue the poor soul hanging from the system. The fact of the matter is that the fall is not the only way to cause injury and/or death. The sustained mobility of being suspended and the potential for the harness to restrict blood flow can cause serious issues if the worker is not rescued within a reasonable amount of time.

A well designed and implemented fall protection plan must consider all of these aspects. Fall protection may or may not be your bread and butter, however when you need it, considering only some of the aspects could turn into a very bad day. All good ideas start with a plan but without the follow through you’re just a guy hanging there hoping on a dream.

Trust the Math for Your Eyes May be Deceived

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 An inside look at why fall protection anchors must be tested

Fall protection!  When you put on your harness, tie off to a fall protection system, and step to the edge of the roof on a 20 foot tall building, do you know that you are truly safe?  Or is this maybe just a false sense of security that you have been lulled into?  Would you feel different if this were a 200 foot tall building?

As we all know, the components of a complete fall protection system are the user’s personal fall protection equipment and a suitable anchor or lifeline to connect it to.  If the system is properly designed, constructed and used, it will ensure that you will walk off the jobsite at the end of the day safe and sound.  As a user, you can only control the “use” aspect of the system so a great deal of responsibility is on you to ensure your own safety.  If you are a gambler, you can take your safety on faith.  However, those who do not want to rely on dumb luck need to know their fall protection system.

First, the simple stuff: your body harness and lanyard.  They should be purchased from a reputable source with readily available design and testing data from the manufacturer.  Utilizing your Fall Protection User Training, you should be able to perform a visual inspection of the equipment to check for damage or excessive wear.  If all looks good, you should feel comfortable that your personal fall protection equipment will do its job.

On the other hand we have the anchor portion of the system – this is not so easy.  You can look for visible signs of damage or corrosion, but the truth of the matter is that in most cases you have no idea what is behind or underneath the anchor itself.  It is in these areas where corrosion hides and maintenance tends to neglect.  The truth of the matter is that if the anchor was not designed and installed properly, no amount of maintenance can make it safe to use!  You may be thinking the anchor is fine and dandy because that steel beam over there is “big”, or that wall looks “solid” . . . there is no way that it won’t hold 5,000 pounds!  This may be true, but as you stand there looking at the “big” steel beam ask yourself this: what is holding the beam in place?  Okay there is a steel column at both ends, but what are they attached to?  If you don’t know, how can you really be sure that “big” steel beam isn’t going to follow you over the edge of the roof if you fall?

OSHA requires that all permanent fall protection anchors must be tested upon installation and be visually observed annually if they are to remain active.  The fact of the matter is that many property owners simply do not know about these requirements as many building anchors are used daily which have never been tested or inspected.  This puts you at risk of injury, and the property owner and your employer at risk of a hefty lawsuit if something were to go wrong.

We were recently involved in a project which involved the load testing of existing fall protection anchors around the perimeter of the mechanical penthouse.  The anchors were installed on the outside face of the brick veneer and consisted of a steel eye welded to the center of an 18”x6”x 1/8” thick steel plate.  The plate was bolted to the wall with two ½” diameter threaded rods and nuts at both ends.  On this particular structure, we could observe that the other end of the connection inside of the penthouse was identical to the connection on the outside.

Existing anchors outside of mechanical penthouse.

Existing anchors outside of mechanical penthouse.


Existing anchors inside of mechanical penthouse

Existing anchors inside of mechanical penthouse.


From the pictures above, you may be thinking it looks like someone clearly put some thought and effort into installing these anchors so they must have been designed and installed properly.  No rust is apparent and the wall appears “solid” . . . why do they need to be tested???  The reason we were asked to test the anchors is because someone didn’t feel like gambling as they prepared to hang off the side of the building and asked the correct question “can I get a copy of the latest testing and inspection reports?”  As it turns out there was no record that the anchors had ever been tested or inspected, and more disturbing that they may have never been designed either.  Fortunately in this case, the property owner and contractor were well aware of the OSHA requirements and requested the anchors be tested before use.

Armed only with a single architectural section of the penthouse wall, we felt it would be prudent to perform a structural investigation prior to performing any testing.  During this investigation we discovered that the two threaded rods were installed adjacent to the light gauge steel studs at most locations.  Running a computer modeled analysis of this configuration yielded results which confirmed that not only were the anchors not suitable for their intended use, but that testing them could potentially damage the building!

Since the existing anchors were determined to be inadequate, new anchors were designed and installed and the old anchors removed and/or taken out of service.  During the testing of the new anchors, we were asked to test one of the existing anchors in a location that a new anchor could not be installed due to equipment conflicts inside the building.  The test was halted at only 1400 pounds as the outside plate had already deflected ½ inch with this minimal load applied to it!


Picture during testing of existing anchor

Picture during testing of existing anchor.


The topic of fall protection anchors is cussed and discussed all the time, but we still have individuals who are either uninformed regarding the OSHA standards or they simply don’t care.  The anchor may look “big”, and that wall may appear “solid”, but the only way to know with certainty that it is safe is through proper testing and annual observation.  As a user, you need to be cognizant of your own safety and simply ask for the latest fall protection anchor testing or inspection report before you go trusting your life to it.  This will provide you with peace of mind, and you may educate someone else about the OSHA standards in the process which may save another life down the road.

Worth Reviewing

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An assessment of the OSHA standards that apply to fall protection for scaffolds and scaffold users and erectors.

Have you ever asked yourself how many ways fall protection can be screwed up, particularly on scaffolds?  Well, based on my experience, misapplication and misuse is only limited by the number of workers on the job.  Rationale doesn’t seem to be a consideration nor does common sense.  I recently testified as an expert in a lawsuit where the employer insisted that the reason the employer did not want the employees utilizing personal fall arrest equipment is because if the suspended scaffold fell it would entangle the employees in the rigging.  Lucky for the employer the employees listened.  Unlucky for the employees, they rode the scaffold down and died in the process.

So why is it so difficult to provide fall protection?  Is there magic?  Nope-no magic; you just have to know and understand how this stuff works.  Let’s review a few things and see if we can sort it out.

Fall protection regulations/standards can be found in a number of references.  In construction, the federal OSHA standards address scaffold fall protection in Subpart L and M.  Well, actually it is addressed in Subpart L, not M.  However, if you are going to use personal fall arrest equipment, then you have to use the applicable standards that are found in Subpart M, namely 29 CFR 1926.502(d).  This is where all the good regulations regarding lanyards, connectors, dee-rings, snaphooks, horizontal lifelines, anchor strength, freefall distance, deceleration distance, maximum arresting force and related topics are hiding.  In fact part of the feasibility test for scaffold erector fall protection is located in 29 CFR 1926.502(d).  Of course, this is where plenty of the confusion starts since it appears the 502(d) standards are either misunderstood, misread, or maybe just not read.  Here are a few of the myths and misconceptions that occur regarding the use of personal fall arrest systems (PFAS):

  • Using (not wearing but actually using) PFAS won’t hurt you;
  • Many people actually use PFAS;
  • Tying off is the same as fall arrest;
  • 100% tie-off works;
  • Scaffold erectors are exempt from fall protection;
  • Scaffold erectors aren’t exempt from fall protection;
  • Restraint is the same as fall arrest;
  • Positioning is the same as fall arrest;
  • PFAS anchors must hold 5,000 pounds;
  • Guessing an anchor can hold 5,000 pounds is acceptable;
  • Nobody knows how much force is exerted on the anchor when an employee falls;
  • The potential loads on horizontal lifeline anchors aren’t very high;
  • The 5,000 pound anchor strength is based on science;
  • You don’t have to be a competent person to determine if another is competent;
  • The Goodyear blimp doesn’t make a good anchor;
  • Money (financial burden) cannot be included in feasibility;
  • There is an OSHA definition for “feasibility”;
  • An anchor that looks good works;
  • A scaffold erector can tie off at her feet, especially if it looks good;
  • Supported scaffolds make good anchors;
  • Supported scaffolds don’t make good anchors;
  • You can tie off to scaffolds;
  • You cannot tie off to scaffolds;
  • All OSHA compliance officers can correctly evaluate PFAS;
  • All scaffold erectors can correctly evaluate PFAS;
  • All employers can correctly evaluate PFAS;
  • 100% tie-off is the same as 100% fall protection.


If you think any of these myths are true, you aren’t the competent person you think you are.  Well, except for the Goodyear blimp thing; that may be true!  The point here is that too many people have the apparent authority to promulgate inaccuracies.  Personal fall arrest is quite simple in theory, difficult in practice.  The freefall distance is a critical component that directly impacts the required strength of the anchor.  Likewise, the deceleration distance has a direct impact on the anchor load.  More freefall and less deceleration distance dramatically increases the anchor load.  (Think jumping into a pool full of marshmallows as opposed to landing on a concrete sidewalk.)  Is insisting that the leading edge scaffold erector tie off at his feet really any better than allowing him to use his skill and experience to minimize the fall hazard through the use of safe erection techniques?

Finally, the fall protection standards work for stationary employees; that is an employee working in one location, rather than walking back and forth over a distance as scaffold erectors tend to do.  A vertical lifeline is not conducive to straying horizontally from the anchor and horizontal lifelines only work if there is no scaffold above you.  Besides, the anchor in a horizontal line can easily see load in excess of 10,000 pounds if not rigged properly; it’s tough to get a scaffold to hold that.

What is a person to do?  Well, for supported scaffold erectors complying with 29 CFR 1926.451(g)(2) would be a good place to start.  This standard requires that the employer have a competent person “determine the feasibility and safety of providing fall protection for employees erecting or dismantling supported scaffolds.”  Of course, this standard doesn’t say that you have the right to tell the competent person that he/she is wrong.  This standard doesn’t say you get to question the decision.  But if you are competent, this standard sure gives you the right to determine if he or she is indeed competent!  In other words, be sure you’re sure before you see if they’re sure.  Think about it.

Where Did The Shoring Go?

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An argument for re-establishing the Shoring & Forming Council in the Scaffold and Access Industry Association.

I recall my first involvement with the Scaffold Industry Association, SIA, in the early 1980’s.  I was impressed by the people who were genuinely involved in making the use of the scaffolding and related products safer.  I also recall how I was railroaded into taking the minutes for council meetings!  In fact, I was inducted (or abducted) into the role of scribe for the Shoring and Forming Council.  You read that correctly.  Back then there was a Shoring and Forming Council.  There also was no Fall Protection Council, Aerial Lift Council, or Hoist Council.  Over the years the focus of the association has changed, evolving into an organization that emphasizes the various forms of access for workers.  Concurrently, shoring and forming slowly diminished in scope and involvement to the point that it is no longer represented in the SIA.

This doesn’t mean that there are no members who are involved with shoring and forming.  It also doesn’t mean that there are no issues with the use of these products.  In fact, there actually is more commonality between scaffolding and shoring than you might think.  On the other hand, scaffolding is definitely not shoring and shoring is not scaffolding.  For this discussion, we’ll leave wall formwork alone except for the fact that the work platform on a wall form is a scaffold and consequently the scaffold standards in federal OSHA 1926, Subpart L apply.

What are the common elements between shoring and scaffolding you may ask?  Well, fall protection is a common element; access is a common element; falling object protection is a common element; and, capacity and strength are common elements.  The significant difference between scaffolding and shoring is that a scaffold is a temporary elevated platform and its supporting structure used to support workers or materials or both.  Shoring, on the other hand, can be a system of structural elements used to support the formwork for concrete (the Jell-O® mold that holds the liquid concrete).  Shoring can also be a system of structural elements used to support existing structures such as buildings while repairs or modifications are being performed.  Since shoring and scaffolding are different structures, different OSHA standards typically apply although there is overlap in a number of areas.  That is where the similarities come into play and thus it makes sense that the SIA should consider resurrecting the Shoring and Forming council.

For example, fall protection for shoring erectors has the same issues as fall protection for scaffold erectors.  For new concrete construction, the shoring equipment is always at the top of building (that is logical) and consequently, there is no convenient anchor above the erectors unless the Goodyear® blimp is in the neighborhood.  Supported scaffolding can have the same issue.  Interestingly enough, a review of the OSHA standards show that the Construction Industry fall protection standards are applied by OSHA through the use of Letters of Interpretation.  Unfortunately, it is a circuitous route that attempts to apply the standards in creative ways so as to justify a desired outcome.  The results are confusing requirements for shoring erectors to contend with during their work.

Access for both scaffold erectors and shoring erectors is an intriguing topic for those who attempt to apply inappropriate standards.  OSHA considers shoring frames to be working surfaces and therefore fall protection and/or positioning devices are required.  If these same frames are used as scaffolding, and they can be, then they can be climbed by the erectors.  Confused yet?  Wait—there’s more!  Access for shoring can really be interesting.  While the erector shouldn’t climb the frame because it is not a ladder but rather a working surface, the erector doesn’t need to comply with the ladder standards because his access continues to move while the shoring is constructed and the access requirements of 29 CFR 1926-Subpart X were never intended to apply to this work activity.  Are you confused yet?

The final frustration is when the compliance officer or site safety employee can’t figure out whether you are working on scaffolding or shoring.  Applying the scaffold standards to the erection of shoring is like trying to apply the fixed ladder standards to a scaffold attachable ladder—it doesn’t work.

The Scaffold Industry Association members have a wealth of experience and expertise that can be used to clarify the intent and application of the standards while making life easier and safer for both the erectors and users of temporary structures.  Is it time to resurrect the Shoring and Forming Council? I think it is.

Industrial Scaffolds – Unique or Common?

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Scaffolds used in locations such as refineries, chemical plants and power stations are often referred to as industrial scaffolds, suggesting they are unique to that environment.  But are they?  Is there something mysterious going on in the refinery that transposes a common scaffold into a magical load bearing wonder that supports workers at heights?  Or is that scaffold just a regular common scaffold similar to a commercial or residential scaffold?

I believe the answer is somewhere in between.  Well, that stuff about a scaffold being transposed is a bit of a reach (no pun intended) but one significant difference between industrial and other scaffolds is that the industrial environment produces scaffold work habits not often seen in the commercial sector.  One conspicuous example is scaffold inspection.  US Federal OSHA requires that scaffolds used in construction be inspected before each workshift by a competent person [29 CFR 1926.451(f)(3)].  In the industrial environment this requirement is taken seriously.  Frequently the inspection task will be assigned to one company although multiple employers may be using the scaffold during that workshift.  More often than not, the scaffold company that erected the scaffold will have that duty.  Of course, this doesn’t mean the scaffold users don’t have to know anything about scaffolds nor does it relieve them of the obligation to use a safe scaffold.  After all, the OSHA standards involve all of us [29 CFR 1926.454].  Once the scaffold is inspected at the beginning of the workshift (notice that it isn’t each day; it’s before each workshift) [29 CFR 1926.451(f)(3)] a record may be made of the inspection.  This record may be a simple tag or it may be as complex as a written record that is retained for the duration of the project.  In conjunction with this method of inspection is the absolute rule that no one modifies, changes, dismantles or messes with the scaffold other than the workers assigned the task of scaffold assembly [29 CFR 1926.451(f)(7)].  Frankly, this is why the sole source inspection and tagging system works in the industrial environment; nobody messes with the scaffold.

Unfortunately, the same cannot be said about the commercial or residential environment.  In fact, most workers on commercial job sites, based on my experience, consider themselves experts in the design and erection of scaffolding and therefore can do whatever they want with the scaffold.  Even when the general contractor attempts to implement the controls seen in a refinery, the controls are typically circumvented by those who have the least knowledge and are consequently most exposed to injuries and death due to unauthorized modification of the scaffold.

Another example of the unique environment found in industrial scaffolds can be seen in the complexity of the constructed scaffolds.  Because of piping, structural elements, electrical lines and other obstructions it takes considerable skill to erect a scaffold in a refinery or power plant.  (Now, before you professional commercial scaffold erectors get mad at me, I’m not suggesting that professional commercial scaffold erectors are not qualified.)  Those charged with industrial scaffold erections typically comply with the OSHA standard that specifies that scaffolds shall be erected by “trained and experienced” workers [29 CFR 1926.451(f)(7)].  Such may not be the case in commercial construction where the painter, who knows how to paint, may know very little about scaffolding but erects the scaffold anyway.  In that case, the scaffold is erected for the convenience of the painter and may not work for the glazer.  Industrial scaffolds, on the other hand, are often erected for all the trades to use or, if that is not possible, the scaffold is dismantled and re-erected.

Environmental controls appear to be more restrictive in industrial applications as well they should be.  However, lessons from the power plant could be learned in the commercial project where we still fight resistance to eye protection, hearing protection and other equipment meant to protect the worker.  As for the residential market, some days it seems hopeless to expect anything.

Fall protection is another aspect of the industrial market that is not as readily appreciated in the commercial or residential market.  It is not uncommon at a chemical plant to not only expect workers to work on fully guardrailed platforms but to utilize personal fall protection equipment and tie off when they get to their work station.  While this is a trend among large general contractors in the commercial construction market, the practice is considerably behind the industrial market in implementation.  And again, when it comes to the residential market, personal fall arrest equipment usage is rarely observed.  (Of course, I’m not endorsing the concept of both guardrailsand personal fall arrest equipment since it is really rather redundant; I’m just describing my observations.)

How about scaffold platforms?  This is interesting since industrial scaffold platforms typically have more obstructions and penetrations than a commercial scaffold will ever see.  While steel plank are more common in industrial scaffolds and plywood is commonly used to cover gaps since the gaps are less tolerated than in commercial installations, it is not uncommon to notch wood plank so it will fit around an obtrusive pipe or conduit.  Commercial scaffolds usually have a clear platform that is easier to erect and use.

Finally, access in the industrial environment is usually more difficult than in the commercial scaffold application.  Attachable/clamp-on ladders are the access of choice for small platforms and limited use in the refinery or power plant since they are easier to install around obstructions.  Of course, where access for a large number of workers is needed, a systems scaffold stairway is commonly used.  Commercial scaffolds will utilize stairs and ladders but also will utilize frame scaffolds and the access these frames provide.  In residential applications access is anybody’s guess and a ladder sighting at a house is a pleasant surprise.

The bottom line however, is that the industrial scaffold serves the same purpose as a commercial or residential scaffold in that it provides a safe temporary elevated platform to support workers or materials or both.  Where the scaffold is erected and used matters not—it still has to be erected and used correctly.

Fact or Fiction

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Fall protection is a huge topic these days what with people falling down and falling from heights.  And since scaffolds are, by definition “any temporary elevated platform,” the issue of fall protection is significant, especially since most scaffold fatalities are due to falls from heights.  It doesn’t have to be this way.  Scaffold suppliers have this really cool product called a guardrail that when used properly, will keep you from falling.  And if you don’t like that, you can always use other stuff to keep from falling to your death.

As you may already know, there are basically two choices when addressing fall protection from scaffold platforms: a guardrail system and personal fall arrest systems.  While not specifically addressed in many safety standards, fall restraint can also be used as a form of fall protection.  Other options are available for fall protection from places like open sided floors and roofs, options that include safety nets, monitoring systems, warning lines and fall protection plans.  It should be noted that lots of safety folks don’t like some of those options since they require workers to behave and we all know that doesn’t always happen.

Experience has indicated to me that when it comes to fall protection, everybody is an expert.  I’m not sure if that is because people fall, making them instant experts, or they think it’s no big deal to “tie off.”  So let’s look at some of these issues and sort out the fact from the fiction.

  1.  Fall protection is required when you are more than 6 feet above the level below.  Fact and fiction!  It depends on the applicable code.  Codes require fall protection at heights ranging from 4 feet to 30 feet.  So find out what the rule is where you are working (or hanging around).
  2. Most workers on construction sites, both commercial and industrial, often use personal fall protection equipment.  Fiction.  Very few workers use personal fall protection equipment.
  3. Many workers wear personal fall protection equipment.  Fact.  Luckily very few workers use it.
  4. Anchors for personal fall protection systems must hold 5,000 pounds.  Fiction.  If the anchor is designed by a qualified person, it must have a safety factor of 2.
  5. If you hook your lanyard (the other end of the rope that is attached to your harness) to an anchor, the anchor must be designed.  Fact.  You cannot guess at the strength of the anchor; if the anchor is not part of a system designed by a qualified person (see #4) the anchor must hold at least 5,000 pounds.  Guessing is not allowed although it appears everybody does it.
  6. The maximum force on the body is limited to 1,800 pounds.  Fact.  This means you better not fall too far before your fall is arrested.  That’s a fancy way of saying that when you reach the end of your rope, the force on your body better be less than 1,800 pounds or there will be two of you.  Incidentally, if the force on your body is limited to 1,800 pounds why does the anchor have to hold 5,000 pounds?  After all, if you pull on one end of the rope with 1,800 pounds, doesn’t the anchor on the other end only have to pull with a force of 1,800 pounds?  Hmmmm-what’s with that?
  7. The 5,000 pound anchor requirement is based on extensive scholarly research and testing. Fiction.  It’s based on the strength of ¾ inch manila rope which is actually 5,400 pounds.  It was lowered to 5,000 pounds in the US federal construction standards to agree with the US federal general industry standards.  So much for science.
  8. You cannot free fall more than 6 feet.  Fiction (sort of).  You can free fall as far as you would like, according to a US federal OSHA Letter of Interpretation.  It’s just that when you get to the end of your free fall, the load on your body cannot be more than 1,800 pounds.  (Now you know how bungee jumping works.)
  9. 100 percent tie off is the same as 100 percent fall protection.  Fiction.  Anybody can do 100 percent tie off; just look at any construction site.  Workers tie off to all sorts of ridiculous stuff.  Like the guy that ties off to the step ladder he is on!  One hundred percent fall protection is easy for scaffold users, but not leading edge scaffold erectors.
  10. I cannot use a scaffold for an anchor.  Fiction.  Some scaffolds make very nice boat anchors.
  11. I can use a scaffold as an anchor.  Fact.  When designed by a qualified person (and perhaps a qualified Professional Engineer) a scaffold can be used as an anchor for a personal fall protection system.
  12. It is difficult to provide adequate anchorage for leading edge erectors and still comply with all the fall protection standards.  Fact.  It’s really tough to get a scaffold to hold 5,000 pounds.  It’s really tough to limit the free fall distance for erectors to 6 feet when they have nothing above them to tie to.  If we waived certain regulations for scaffold erectors, we would eliminate some of the excuses.  For example, is it really necessary for scaffold erectors to have an anchor that can hold 5,000 pounds?  Is it really necessary that the system have a 2 to 1 safety factor.  After all, as long as he/she doesn’t fall to a certain death have we not succeeded?  Something to think about.
  13. Horizontal lifelines are easy to install and use.  Fiction.  While they may be easy to install, they are not easy to use.  The problem with horizontal lifelines is that people never use them.  That’s right; they install them, and hook off but luckily never use them.  If they used them they would be terribly disappointed in the performance of the line.  There is a reason horizontal lifelines are to be designed by a qualified person.  Did you know that an anchor on a horizontal lifeline can see a load of 25,000 pounds if it is not designed properly?  What do you suppose that would do to the scaffold?
  14. All safety consultants and compliance officers are experts in fall protection design and installation.  Fiction.
  15. All scaffold users are experts in fall protection design and installation.  Fiction.
  16. All scaffold erectors are experts in fall protection design and installation.  Fiction.

So much for fall protection– I still think the easiest fall protection is:  Don’t fall.  But then perhaps there’s more fiction in that statement than fact!

Random Numbers

By | Fall Protection, OSHA Standards & Regulations, Resources, Scaffolding | No Comments

As a prime example, take the standards that relate to the height of toprails in a guardrail system.  Here are the numbers: 36; 38; 39; 42; 45; 48.  How about the height above the level below when fall protection is required?  Here are the numbers:  5 feet; 6 feet; 7 and a half feet; 10 feet; 15 feet; 30 feet.  And just for fun, midrails on a guardrail system are to be either “halfway” or “approximately halfway” depending on which standards apply.  (Can you imagine the “halfway” concept: off by 1/64th of an inch and you just violated the standards!)

Dimensions and measurements are not limited to fall protection but these numbers typify the contradiction in the industry.  It is particularly nasty for those who “just want to build scaffolds” as one frustrated scaffold erector told me.  So, how random is it?  Let’s take a look at the height at which fall protection is required.  The OSHA Maritime standards require fall protection at 5 feet while the OSHA construction standards require fall protection at 6 feet except for scaffolds where the height is 10 feet.  The Army Corps of Engineers, in their recently updated standards, determined that fall protection should be required at 6 feet for all situations including scaffolding.  Apparently things are more dangerous in military construction after all.  Or maybe workers on construction scaffolds know how to fall safely.  Actually there may be a legitimate reason why guardrails are not required for scaffolds until 10 feet above the level below.  It’s based on the increased hazard of attempting to work from scaffolds in the typical commercial ceiling height environment while contending with a guardrail system.  Why the Army Corps chose not to agree with that is unknown to me.  But then, as far as I know, the Army Corps didn’t ask anybody in the Scaffold Industry Association for any comments regarding the revamped Army Corps standards.

What’s interesting about all of this is the apparent lack of solid scientific data to support the numbers.  It is often argued that death can occur from any height—and it’s true.  For example, I am aware of a worker who fell backwards off a scaffold platform approximately 4 feet above the ground.  He unfortunately hit his head on a concrete block and died instantly.  But, on the other hand, you hear about workers who fall from 20 or 30 feet without any lasting injuries, much less death.

So where do the numbers come from?  Based on my research, it appears that much of it extends from earlier standards and codes; unfortunately, the real, original basis for these disparate numbers is lost to history.  In other words, we seem to perpetuate the randomness of the numbers.  I don’t particularly have a problem with that.  For example, 42 inches seems to be a good number for a guardrail height.  (Far be it for me to argue what so many people agree is the right height.  Besides, I don’t have any research to argue that 42 inches isn’t a good height. However, I wonder what the National Basketball Association might have to say about it.)

The real mystery here is why there is so much variability in the required heights and distances.  Why does California insist on a 7’-6” height while the rest of the country is at 10 feet?  Why do the Maritime standards insist on a threshold of 5 feet and the Army Corps of Engineers insist on 6 feet?  The erector I mentioned earlier erects scaffolds in California, Arizona, Nevada, Washington, and Hawaii.  One week he may be erecting scaffolding in a shipyard in Washington (Maritime applies) or maybe at an office building in Seattle where Washington OSHA (WISHA) standards apply.  The next week he may be in the middle of California working on a scaffold at a water treatment plant where California OSHA (Cal/OSHA) standards apply.  But if he is on a Native American reservation in the middle of California, the federal standards apply.  Hopefully he doesn’t go next door to the US Army VA hospital because the Army Corps standards apply!  Unfortunately, the following week our confused erector is in Nevada working on a casino in Las Vegas and since Nevada is a “state plan” state, he must know the nuances of Nevada’s standards.  From there our erector goes to Arizona which is also a state plan state with its own peculiarities.  Hopefully our erector doesn’t have to travel to Hawaii anytime soon; it’s a state plan state too with the potential for variations in the applicable standards compared to other jurisdictions.

Surprisingly, it appears that most, if not all, the standards agree on one thing: the strength of the toprail shall be no less than 200 pounds.  If we can agree on that, why can’t we agree on the rest?  Oh, by the way, those numbers I listed at the beginning of this article are all real and correct.  Do you know which standards they came from?

Hot Wheels

By | Fall Protection, OSHA Standards & Regulations, Resources, Scaffolding, Scaffolding Platforms | No Comments

As with all scaffolds, there are design, construction, and safety issues with mobile scaffolds.  The idea here is to discuss some engineering issues, leaving the obvious safety issues to the “competent person, qualified in scaffold construction.”  Now that I think about it, perhaps the safety issues aren’t so obvious so let’s cover those first.  Make sure you have fall protection, falling object protection, access, adequate strength, a decent platform that remains in place, and don’t do something stupid.  Now that we have the safety features in place, proper design, in combination with proper use, makes the mobile scaffold such an excellent productivity tool.

What is it that makes the mobile scaffold safe, or conversely, unsafe?  The center of gravity, an engineering term that describes the stability of a mobile scaffold, is one significant factor.  Another factor is the strength of the casters and other components.  Another factor is the forces required to move the scaffold.  These forces are horizontal, vertical or both.  A qualified designer of mobile scaffolds must consider these factors, and of course the user of the scaffold must understand how to safely drive the scaffold (or at least push it around).

The Construction Industry scaffold standards from the Federal Occupational Safety and Health Administration, OSHA, address these issues as does both the American National Standards Institute, ANSI, scaffold standards and the Scaffold Industry, SIA, Codes of Safe Practice.  Specifically, the federal standards, of which the construction standards are the best source, identify the hazards described above, that is stability, strength, and dynamic forces.

What is the significance of the strength of the various components?  Well, I doubt you want the scaffold collapsing while you are on it.  Therefore you need to know your limitations.  The typical scaffold caster is usually the limiting factor.  Hallway scaffolds, those narrow scaffolds commonly used by drywall installers, have a capacity of about 250 pounds.  Frame scaffold casters, on the other hand, will have a capacity of approximately 500 pounds unless you buy one of those cheap casters of unknown capacity.  Larger frame scaffold casters, and those used with systems scaffolds will have a capacity in excess of 1,000 pounds.  These caster capacities are usually adequate for most mobile scaffold uses and are almost always less than the leg capacity unless, of course, you buy one of those cheap scaffolds of unknown strength.  The bottom line is to find out what your caster can hold before the ball bearings begin to fall out!

The stability of the scaffold is very important to the occupant of the scaffold for apparent reasons.  It’s just not a good idea to have the scaffold fall over, whether it is occupied or not.  How do we ensure that it won’t tip?  By making it big enough and not pushing it over.  If the mobile scaffold has a big enough base, both in width and length, the scaffold will remain standing, absent any other forces.  Except for California, the maximum height to base ratio is 4.  (In California it’s 3 to 1 and no, it’s not because they have earthquakes.)  This means the height can be no more than 4 times the minimum base.  For example, if you have a mobile scaffold that is 5 feet wide by 8 feet long, the maximum height is 5 feet times 4 equals 20 feet.  If you want to go higher, then make the base bigger.  But be careful – you may be overloading the casters because of all that extra scaffold weight.  The sky is the limit, no pun intended, but the higher you go the heavier it gets and pushing it around gets to be a real challenge.

How much does it take to push over a mobile scaffold?  The snappy answer is: not much.  The force needed to move the scaffold horizontally and the force needed to push it over are not the same although the untrained scaffold user may inadvertently be applying a force to knock it over all the while thinking that she is applying the force to move it horizontally on the floor.  Worse yet, if the casters aren’t rolling, due to maybe a small obstruction, a horizontal force at the top of the scaffold will quickly become a force that will knock the scaffold over.  In engineering terms, we call that instability.  For the user who is riding the scaffold down to disaster, it may be referred to in other terms.  Here is what is going on.  When you push against the side of the scaffold, you are trying to get the mass of the scaffold moving.  If you push close to the bottom of the scaffold, all your efforts will go to moving the scaffold.  As you push more, the scaffold slowly begins to move, converting a static (non-moving) condition into a dynamic (moving) condition.  The weight of the scaffold obviously influences the amount of force needed to get the scaffold moving.

Now, another factor comes into play here; the center of gravity.  The center of gravity is an imaginary point in the scaffold that is defined as the center point of all the vertical loads of the scaffold including the scaffold components, platforms, and the folks on the scaffold.  Typically, this point is in the middle of the scaffold but if there are cantilevered platforms the center of gravity will shift towards the direction of the cantilever.  If the cantilever is big enough, or the weight on the cantilever is big enough, or the folks on the scaffold are leaning out over the guardrail, the center of gravity shifts to the outside of the scaffold base, and the trouble begins.  The users get real excited because it is at this point that the scaffold begins to tip.  The same thing can happen when the scaffold is pulled along from the top by grabbing onto the roof trusses, for example.  While it may take a force of say 100 pounds to get the scaffold going, if the bottom isn’t going anywhere and the top is, the center of gravity begins to shift and the force needed to pull the scaffold over reduces to as little as 20 pounds; this is when the scaffold begins to tip.

Right about this time, the errant user has just experienced basic physics and now realizes the error of his ways. He begins to head to the other end of the scaffold in an attempt to makes things right.  Unfortunately he forgot to pin the casters into the scaffold leg and they fell out during the tipping maneuver;  the rest of the story gets real ugly.  And that is why the OSHA standards require that: “Manual force used to move the scaffold shall be applied as close to the base as practicable but not more than 5 feet (1.5 m) above the supporting surface.”  That is also why the standards also require you to pin the casters to the legs.

And what about surfing the scaffold—the technique of “jerking” the scaffold so it moves horizontally?  What do you suppose that does to the forces and stability of the scaffold?