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Industrial Scaffolds – Unique or Common?

By | Fall Protection, Guardrail, Resources, Scaffolding, Scaffolding Platforms | No Comments

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

By | Fall Protection, Guardrail, Resources, Safety Hazards, Scaffolding, Scaffolding Platforms | No Comments

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!

Cheap Paint

By | Aerial Lifts, Fall Protection, Guardrail, Resources, Safety Hazards, Scaffolding Platforms | No Comments

A friend of mine, when he first got involved in the aerial lift rental business, wondered why the aerial lift manufacturers used cheap paint on the guardrail systems.  Every time he rented a scissor lift, the paint was worn off the top of the rails when the unit was returned.  It didn’t take too long in the rental business however, for my friend to figure out that the paint was being worn off because the users were using the mid and top rails as platform supports.  In other words, the scissors lift users were improperly using the machine.  I have had the same experience; users often tell me it is the only way they can get the work done.  I even had one employer tell me that he tells his workers to use personal fall arrest equipment on scissors lifts so that when they climb on the guardrails, they are protected from falling.  Now there is a conscientious employer!  Amazingly enough, just the opposite happens with boom lifts (correctly known as “Boom Supported Elevating Work Platforms).  Sine there is a guardrail system around the platform or basket, some users assume that fall protection is provided, never considering the possibility of being launched out of the basket or platform due to a possible catapulting action.

Have users never thought about the consequences of using an aerial lift improperly?  There is the obvious consequence of falling from heights.  But what are some of the other consequences?  I dare say that we are now seeing the results of the misuse of aerial lifts.  Let’s consider the scissors lift, a versatile machine that mechanically raises and lowers a platform so the worker can access the work area quickly and conveniently.  The platform, typically no bigger than the wheel base of the machine, is lifted by arms that operate in a scissor like action.  The platform is stable with minimal sway and no redundant vertical motion once the platform is in position.  A guardrail surrounds the platform, protecting the worker from accidentally walking off the platform.  The guardrail system is always at the correct height, assuming the worker is standing on the platform and not cleverly standing on a bucket or other makeshift device to gain height.  Through the use of the guardrail system fall protection is provided.  Nothing else is required.  This guardrail system is the same as the guardrail system found at stadiums, auditoriums, bridges, balconies, decks and homes.  If this is an acceptable system at these facilities, why then do safety people and compliance officers insist that personal fall arrest equipment be used by scissors lift occupants?  Why are manufacturers installing anchors in scissors lifts?  What good is a platform that is 8 feet wide and 12 feet long when I am attached to an anchor with a lanyard that will only allow 5 or 6 feet of movement?  Frankly, it doesn’t make any more sense to “tie off” in a scissors lift than it is to tie off when I am standing on the balcony in my house.

But what makes this whole concept truly absurd is that the occupants tie off to the guardrail.  Let’s see, the guardrail can hold 200 pounds and if the occupant decides to fall, not only will he break the guardrail, but will probably bring the whole machine down on top of him, adding embarrassment to the injury.  Can this get any crazier?  Well yes, it can.

Let’s look at boom lifts.  The occupant hops in to take it up to do something quick, not thinking about the need for a personal fall restraint system.  That’s right, I said fall restraint.  We want you, the user, to stay in the bucket.  Utilize a long lanyard and you’ll feel like an astronaut, for six feet.  Then if you’re lucky, you’ll get left hanging around; if you’re not so lucky, you’ll bring the machine down on top of you.  Neither option is healthy.  Think about this: Who is the individual most exposed to the catapult action but doesn’t know it?  Who is the least likely to go through the effort of wearing a full body harness and short lanyard to move the machine only a few feet?  You’re correct if you said the truck driver.  She thinks that since the machine is only going onto the truck, there is no danger of falling.  On the contrary, there is a real likelihood that as the machine is driven onto the truck, it will tip and catapult the operator out of the basket, resulting in a real surprise at best, and a broken neck at worst.

Manufacturers are responding to all of this in a positive, constructive way.  Anchors are showing up on scissors lifts so that if you choose to wear fall restraint/protection, a suitable anchor is available.  Boom lifts are being designed to be more stable and capable of resisting flying occupants.  So, how do you know what to do?  It’s easy.  Read the manual that is located on the machine.  It will tell you amazing things that you may not know, such as what is required for fall restraint/protection.  Can it get any easier than this?  Get the training that is required before you operate an aerial lift.  And don’t do stupid stuff.

Finally, no thanks to all who have not used an aerial lift correctly.  You have managed to confuse a simple process to the point where perceptions and myths override common sense and personal responsibility.  Due to the misdeeds of a few, many are punished.  The Scaffold Industry Association has excellent information that you should have if you use aerial lifts.  Contact them; they’ll tell you all about it.

General Industry or Construction?

By | Guardrail, OSHA Standards & Regulations, Resources | No Comments

The US Federal Occupational Safety and Health Administration, OSHA, has promulgated scaffold standards for both general industry and construction.  While the scaffold equipment is common to both applications, the standards are not.  First, the standards are written in two different styles.  The construction standards are performance oriented while the general industry standards are specification oriented.  Second, the construction industry scaffold standards are stand alone standards, designed to address only scaffolds.  On the other hand, the general industry standards are included in Subpart D – Walking-Working Surfaces.  Besides scaffolding, Subpart D also includes stairs, ladders, and other working surfaces.  Finally, the construction industry standards were revised in 1996 while the general industry standards await revision and updating.

What determines which standards to use?  Although there is no hard rule that determines when construction or general industry standards apply, here are several guidelines to evaluate your specific situation.  If the work being done is maintenance and done with “in-house” employees, the general industry standards apply.  If the work being done is a modification of an existing situation then the construction industry standards could apply.  For example, in a power plant various valves and piping are being replaced with identical members and a scaffold is being used to access the area.  In this case, the general industry standards would apply.  On the other hand, if the valves and piping are being replaced, modified, added to and expanded, then the construction standards apply.  Also, if an outside contractor is employed to do the work, the construction industry standards probably apply. You can go to the OSHA website, www.osha.gov to obtain Letters of Interpretation addressing the issue of general industry standards versus construction industry standards.

Here are selected differences between the general industry and the construction industry scaffold standards:

 

  1. The general industry standards require that scaffolds and their components have a 4 to 1 safety factor.  The construction industry standards require that scaffolds support their own weight and 4 times the maximum intended load;
  2. The general industry standards require that any scaffold damaged or weakened from any cause shall be immediately repaired and shall not be used until repairs have been completed.  The construction industry standards allow continued use of the damaged scaffold provided the damaged equipment is adequately braced to properly support the intended loads;
  3. The general industry standards require the use of scaffold grade planking.  The construction industry standards do not;
  4. The general industry standards require that plank shall extend over their end supports not less than 6 inches nor more than 18 inches. The construction industry standards require a minimum of 6 inches and not more than 12 inches for plank 10 feet or less in length and not more than 18 inches for longer plank.  The construction industry standards also allow shorter and longer overhangs if the plank is secured from movement;
  5. The general industry standards require overhead protection for workers exposed to overhead hazards. The construction industry standards allow other options for falling object protection, such as barriers, catch platforms, and solid guardrail systems;
  6. The general industry standards require screening between the toeboard and the guardrail where persons are required to work or pass under the scaffolds.  The construction industry standards allow other options for falling object protection such as barriers, catch platforms, and solid guardrail systems.

This describes the major differences between the two standards that apply to the general requirements for scaffolds.  There are also some variations when it comes to specific scaffolds.  For Tubular Welded Frame Scaffolds, for example, these are the differences:

  1. The general industry standards require the use of a guardrail system and toeboard.  The construction industry standards allow the use of a guardrail system or a personal fall protection system.  Also, other forms of falling object protection, besides toeboards, are allowed;
  2. The general industry standards require that the toprail be installed between 36 and 42 inches.  The construction industry standards require the toprail to be installed between 38 and 45 inches;
  3. The general industry standards require that all frame scaffolds be erected by competent and experienced personnel. The construction industry standards require that scaffolds be erected under the supervision of a competent person qualified in scaffold erection, using experienced and trained employees.
  4. The general industry standards require periodic inspections of scaffold equipment.  The construction industry standards require inspections by a competent person prior to each workshift.

This short dissertation illustrates the significant differences between the requirements of the two standards; use it to recognize that you cannot take the general industry standards and apply them to a construction industry application or use the construction industry standards in a general industry application.  It is necessary to identify which standards apply for the specific application.  And of course, no matter which standards apply, it is a safe scaffold that is required.

How are we Doing?

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

In January of this year I wrote an article titled “A Better New Year?” The article described fatality statistics in the construction industry. If you will recall, in 1997 there were almost 700 fall related deaths which means that, on average, there were at least two deaths per workday attributed to falls! OSHA statistics indicate that typically 19 per cent of these fall fatalities were from scaffolds; in other words, approximately every two workdays a worker dies due to a fall from a scaffold.

 

Needless to say, there’s room for improvement. The Federal Occupational Safety & Health Administration, (OSHA), has addressed this concern in both Subpart M, Fall Protection, and Subpart L, Scaffolds, by issuing standards that set the minimum requirements for fall protection for exposed workers. While there are a number of methods for minimizing fall hazards, Personal Fall Protection Systems and Guardrail Systems are two of the most common methods that are used. Interacting with these two methods is another aspect of fall protection that is equally important as the hardware, and that is training.

 

Remembering that fall protection has been required for users of scaffolds since at least 1971, (and certainly before that if you choose to comply with the American National Standards Institute (ANSI) standards), it should be amazing that any scaffold users fall from scaffolds. And yet, we haven’t figured it out yet. Users are still falling in spite of all the requirements. Erectors are falling too. Again, using the OSHA statistics, 11 per cent of scaffold fall fatalities are erectors. That works out to about one erector every three weeks who dies falling off a scaffold. Seems to me that this fact would be good justification for addressing fall protection for erectors.

 

Safety on the jobsite is based on a number of assumptions. The first assumption is that the standards, regulations, guidelines, and practices are correct and accurate. The second assumption is that the regulations are enforced equally, accurately, and correctly. The third assumption is that those responsible for enforcement are knowledgeable and properly trained. The fourth assumption is that workers are properly trained, knowledgeable, and conscientious. The fifth assumption is that the equipment is designed, manufactured, installed, and used correctly. The sixth assumption is that the first five assumptions aren’t necessary for jobsite safety. Therein lies the problem. If any of the first five assumptions is considered invalid, and consequently not met, safety is compromised and fatalities occur.

 

Are we assuming too much? Is it possible that the standards are inadequate and that these standards somehow cause fatalities instead of preventing fatalities? As far as I know, there is no evidence of inadequacies in the standards; therefore we are not assuming too much in expecting the standards to be minimum expectations for behavior.

 

It may be too much to expect equal enforcement of the standards but that has more to do with how often we choose not to meet the standards. In the case of fall protection, we may choose not to employ fall protection measures for a variety of reasons, some valid, some not. Obviously, to say fall protection for erectors cannot be done is the easy answer to a complex question. On the other hand, requiring workers to tie off without a thorough analysis of the situation is equally as hazardous. Consequently, proper evaluation and accurate enforcement of the fall protection standards requires trained personnel, which leads to the third assumption.

 

How can we expect proper enforcement if we don’t give the enforcers proper training and tools. Is it reasonable to expect anyone to have a thorough knowledge of all the standards, especially when we (that’s all of us) don’t provide funding for the training? How well do you know the standards? Do you know how many there are? I believe that the individual charged with the implementation of compliance with the standards and regulations has a formidable job! In fact, to assume that any individual can master all the standards is unrealistic.

 

Assuming that the workers are properly trained is a huge assumption that is rarely fulfilled. The evidence shows that we have a long way to go in getting the worker to use proper fall protection, in getting the scaffold erectors to understand proper fall protection techniques, and getting owners to cooperate in providing the hardware so that fall protection can be provided. What’s the evidence? A death every two workdays.

 

The fifth assumption, that the equipment is designed, manufactured, installed and used correctly assumes many things. While fall protection equipment typically is designed and manufactured to a high degree of sophistication and reliability, improper installation and use can, and does, negate those qualities. Since the user may be untrained, the installation, and therefore the use, of the equipment may be wrong. If all that is wrong, then the potential for death greatly increases, proving that the best efforts by some can easily be negated by the incompetence of others.

 

Finally, assuming that proper standards, proper enforcement, proper training, and proper equipment are not necessary, is the biggest mistake. We are all in this together, whether we like it or not. What have you done this year to ensure that the standards are accurate, the implementation of those standards is accurate, that those charged with the implementation have the training and tools to do so, that the workers are properly trained, (as required by the standards,) and the equipment is used properly? Good fall protection equipment is useless in the hands of untrained users; good fall protection standards are useless in the hands of untrained users. So, how are we doing?

FREQUENTLY ASKED…

By | Guardrail, OSHA Standards & Regulations, Resources, Scaffolding | No Comments

Here are frequently asked questions concerning scaffolding, applicable standards and regulations.

 

What is a competent person?

By definition, a competent person is basically an individual who can identify a hazard and has the authority to take corrective action. While the competent person may not have the solution to minimize or eliminate the hazard, the competent person can consult a qualified person to get the solution.

 

Why should scaffolds be constructed under the supervision of a competent person?

There are at least two reasons. First, a competent person will have the knowledge to identify existing and potential hazards and have the authority to eliminate or minimize those hazards. Secondly, there is a law that says that all scaffolds shall be constructed under the supervision of a competent person.

 

What does “shall” mean in the Federal OSHA standards?

“Shall” means mandatory. In other words, “you gotta do it!”

 

Does Federal OSHA require all scaffold erectors be competent persons?

No. All erectors shall be trained and experienced; the supervisor shall be competent.

 

When is access required for a scaffold platform?

Access is required whenever the height between levels is more than 24 inches.

 

Can you climb out a window or off of a catwalk to access a scaffold platform?

Yes you can, provided the platform is no more than 24 inches above or below the point of access, and the platform is no more than 14 inches horizontally from the point of access.

 

Are guardrails required on all scaffold platforms more than ten feet above the level below?

No, but fall protection, either personal fall protection equipment, or a guardrail system, is required.

 

How strong does a guardrail have to be on a supported scaffold?

The toprail shall withstand 200 pounds in any direction except up on the rail, and the midrail must withstand 150 pounds in any direction except up at any point on the rail.

 

Do all supported scaffolds need a base plate?

Absolutely, unless the scaffold is a mobile scaffold in which case you shall use locking casters.

 

How wide does a scaffold platform have to be?

The minimum width of a platform is 18 inches unless you can show that an 18 inch wide platform will not fit in the space allotted. There is no maximum width of platform.

 

Do scaffold erectors have to always use personal fall arrest equipment?

No.

 

Who determines if erectors must use personal fall arrest equipment?

The employer’s competent person determines in the erectors shall wear and use personal fall protection equipment.

 

Is it a good idea to use scaffold grade plank?

It is an excellent idea! The SIA strongly encourages the use of scaffold grade plank unless the plank being used has been designed for such use by a qualified person.

 

Can scaffold equipment of various manufacturers be intermixed?

Manufacturers discourage intermixing equipment because of the risk of incompatible equipment. The SIA approves of equipment intermixing only if the equipment is compatible. In other words, if you don’t know the hazards of intermixing equipment of various manufacturers, don’t do it.

 

Is it necessary to train scaffold erectors?

Yes; it is required by law.

 

Is it necessary to train scaffold users?

Yes; it is required by law.

 

Does Federal OSHA require all scaffolds to be designed by a qualified person?

Yes.

 

Is continuous cross bracing required on all frame scaffolds?

No. While it is a good idea to install continuous bracing, and manufacturers recommend it, continuous bracing is not required provided proper bracing is installed. If you don’t know what proper bracing is, install continuous bracing.

 

Are clamp-on ladders considered “fixed” ladders and consequently must comply with Federal OSHA Subpart X standards?

No. Clamp-on ladders are a scaffold component and consequently are addressed in the scaffold standards, Subpart L. Clamp-on ladders are not fixed ladders.

 

How far above the platform should the ladder extend?

Unless there is a handhold such as an access gate panel or other hand grab, good construction practice suggests the ladder should extend above the platform about 36 inches. There are no Federal OSHA scaffold standards that specify a height unless a portable ladder is used. If a portable ladder (manufactured extension, fixed length, step, or job-built ladder) is used, the minimum height above platform is 36 inches unless the ladder is secured and a hand hold is provided.

 

When are toeboards required?

Toeboards are one form of falling object protection when there is a danger of injury to workers on lower levels of the scaffold. Other forms of falling object protection include canopies, barriers, screens, and catch platforms.

 

Who determines safe access for scaffold erectors?

The competent person makes the determination.

 

Is it okay to climb over the guardrail to access a platform?

Yes, although an access gate panel would make access a lot easier.

 

Federal OSHA requires for erectors that “hook-on or attachable ladders shall be installed as soon as possible as scaffold erection has progressed to a point that permits safe installation and use.” If the erectors are constructing a stair tower and installing the stair units as the tower is constructed, do the erectors have to install a ladder to be in compliance with the standards?

I would certainly hope not! Look at the intent of the regulation. Its intent is to protect the erector as best as possible. Stairs would provide that protection.