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OSHA Standards & Regulations

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.

Solid Platforms

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

It is true that a scaffold without a platform cannot be a scaffold since a scaffold is defined as a “temporary elevated platform and its supporting structure.” It can, therefore, be assumed that a platform is rather important. But it isn’t the OSHA standards, or any other regulations and guidelines that make a scaffold platform important; it is the absolutely critical nature of a platform that makes it imperative that scaffold designers, erectors, and yes, users fully understand what makes a scaffold platform safe for use. So, what makes a platform safe and how is its safety assured prior to placing the platform and its supporting structure to use? Let’s explore those issues through a series of frequently asked scaffold platform questions:

What materials can be used to construct a scaffold platform?
Anything can be used to construct a platform. Common materials included solid sawn wood members, manufactured wood products, aluminum, steel, fiberglass and plastic. In fact, even cardboard and concrete could be used although I doubt the erectors would appreciate installing concrete panels!

If solid sawn lumber is used to construct a platform, does it have to be “Scaffold Grade”?
It depends. Some standards, such as the U.S. Federal OSHA General Industry Standards, 29 CFR 1910, require the use of scaffold grade plank while the U.S. Federal OSHA Construction Industry Standards, 29 CFR 1926, do not. When designing for a construction industry application, if you are a qualified designer who can calculate lumber stresses and control the loads that will be applied to the lumber, then you can specify any wood you desire provided the lumber maintains a safety factor of at least 4 [29 CFR 1926.451(a)(1)]. Having said that, the Scaffold & Access Industry Association, SAIA, the Scaffold, Forming & Shoring Institute, SSFI, and industry professionals encourage the use of scaffold grade plank when using solid sawn lumber.

Do all planks have to extend (overhang) their supports by 6 inches minimum and 12 inches maximum?
No. If the plank is secured from movement so that the individual plank cannot slide off its support, it does not have to extend a minimum 6 inches over its support. Conversely, it can extend further than 12 inches (in some jurisdictions the maximum overhang is 18 inches) if the plank is secured from movement, including uplift. Of course the plank has to be designed so the use of a long overhang doesn’t result in an overstressed plank.

Which jurisdictions allow an 18 inch overhang?
If you are a scaffold designer, erector, inspector or user you should know the answer to this question. If you don’t know, get training for your jurisdiction. For example, federal OSHA allows overhangs up to 18 inches for plank longer than 10 feet, California allows 18 inches for any length plank and the US Army Corps of Engineers limits all plank overhang to 12 inches, regardless of plank length.

I have been told that nailing plank damages them. Can you nail plank together to keep them from moving?
Of course you can—its wood! If you pound in the nail in the same spot for a long time you’ll probably damage the plank but you really have to keep hammering it.

Is it true that you cannot install plywood on top of plank?
No. While at one time US federal OSHA issued a Letter of Interpretation (LOI) that claimed that you could not install plywood on top of plank, it was rescinded (the LOI went away). Keep in mind that once plywood is installed on top of plank, the plank become “joists” just as 2×4’s or 2×10’s (plank standing on edge) would be.

Speaking of joists, what can be used to support a plywood deck?
You can use whatever works. That doesn’t mean slapping down whatever is available—it means anything that works; any structural member that is designed by a qualified person (see US federal OSHA standard 29 CFR 1926.451(a)(6)) can be used. This includes solid sawn lumber, laminated veneer lumber, aluminum joists, steel beams, and tree trunks if you can figure out how strong they are.

Can I use balsa wood?
Sure, as long as it has the sufficient strength.

US federal OSHA specifies that a platform cannot deflect any more than 1/60 of the span when loaded. [29 CFR 1926.451(f)(16)] Does this apply to the typical manufactured plank that is made out of aluminum and has hooks on each end for hooking over its supports?
You it does. However, based on my experience, if your 10’-0” aluminum platform unit deflects 2 inches due to the load, you may have a serious overload problem.

A common practice is to install a “skip plank” platform where the plank are spaced at about 19 inches on center, resulting in a platform where every other plank is removed. This of course is covered with plywood and requires only half the plank to construct the platform. It has been claimed that a skip plank platform is as strong as a fully decked platform, especially because it seems to not deflect as much. Is this true?
How can it be as strong if it has half the plank? It just seems that way because the plywood helps to distribute the load to more than one plank, making it feel stronger. Don’t fool yourself—it is half as strong. Actually it is less than half as strong since the plank have to support the plywood.

You have mentioned plywood several times now. What thickness plywood is needed for a scaffold platform?
I cannot answer that. It all depends on the members supporting the plywood and the spacing of those members. Remember, and this is important, just because the plank supporting the plywood span 10 feet, doesn’t mean it is a “light duty scaffold.” Your platform must be designed by a qualified person, a person who knows how to calculate loads, use charts accurately and/or have the ability to “solve the problem.”

Can particleboard, oriented strand board (OSB) or flake board be used as a platform?
Sure. See the answer above about designing platforms.

Is there such a thing as an “OSHA approved plank”?
Nope. OSHA doesn’t approve any product. It is up to you to use the plank properly. If you don’t know how to do that, get some training.

Scaffolding Scores High – Unfortunately!

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

Once again, scaffolding has shown its ability to frequently receive OSHA citations!  In fact, it shows up in the number three spot on the famous “OSHA’s 2014 TOP TEN Most Frequently Cited Violations” list.  (See Figure 1) According to OSHA, there were 4,543 scaffold violations: that’s about 17 every workday.  Unfortunately, it is unclear as to the breakdown of the citations; which hazard does each citation specifically address.  (Note that Fall Protection still holds the number one position with 7,170 citations, about 27 per workday.  Again, it is unclear what type of fall hazard existed that warranted a citation.)

How about having some fun with statistics?  While 17 scaffold violations per day is significant, it is worth comparing the 17 violations per day to the number of workplaces and workers in the construction industry.  According to OSHA, there were 89,664 inspections in 2013, about 345 each work day across the United States and its territories.  That works out to approximately six per state/territory each day.  Depending on the population of the state where you do business, this may or may not have you concerned.  Since there are 8 million worksites containing 130 million workers, the odds of having an inspection at least once in a year is one percent.  Does that mean that for every scaffold the same odds exist?  Yes and no.

Not every worksite has a scaffold so those sites should be excluded from the count.  And since the 8 million worksites include construction, manufacturing, retail and a zillion other worksites, an adjustment needs to be made if only the construction sector is to be considered.  So, as an example, let’s assume (guess might be a better word) that twenty percent of the work sites are construction related and that seventy five per cent of those construction sites have scaffolding.  That means that there are 1.6 million construction projects and that 1.2 million have scaffolds.  Obviously the scaffolds will vary in size based on the scope of each project.  While on one site only a small rolling tower may exist, on another site a scaffold 150 feet tall may have been constructed.  For argument’s sake, let’s argue that on average each site has a supported scaffold that is 7 tiers high and 100 feet long.  (Of course any of these projects could have aerial work platforms and/or suspended scaffolds but these scaffolds will not be considered for this example.)  Depending on the equipment being used, the scaffold could have more than 1,000 components.  This would then mean that there could be 1,000 problems which in turn have the potential of creating 1,000 citations.  Since we assumed that there are 1.2 million jobs with scaffolds, and each job has 1,000 scaffold components and potentially 1,000 violations, there are then 1,200,000,000 (that’s 1 billion, 200 million) possible violations looking for citations.  This number suggests that since there were only 4,543 citations, either the compliance officers aren’t doing a very good job or only 0.0004 % (that’s four-ten thousandths) of scaffolds had problems.  Since OSHA compliance officers do a good job, it can only be concluded the industry is doing a superb job of constructing and using scaffolding since 99.99962% are flawless!

Although one could reasonably assume that there may be a flaw or two in this analysis example, the fact still remains that the overwhelming majority of scaffolds are constructed properly.  Therefore it is time to step back and consider whether the present method of measuring safety is accurate since it is well known that accurate measurement is critical if the root cause of scaffold accidents is to be determined.  Furthermore, how can full safety be achieved if the problem isn’t understood?

Historically, scaffolds have been considered to be dangerous and downright life threatening.  This perception assuredly contradicts the evidence:  How can scaffolds be dangerous if 99.999% of scaffolds are constructed without flaws?  Furthermore, how can scaffolds be dangerous if each scaffold is designed and constructed properly?  A properly designed and constructed scaffold has no hazards.  And please, don’t tell me that you can still fall off a properly constructed scaffold.  A properly constructed scaffold won’t let you fall off—you’ll have to jump.

On the surface, the “OSHA Top Ten” continually paints a bleak picture for scaffold safety.  But this analysis shows that it is just not true.  Unfortunately the statistics are taken at face value without considering the bigger picture.  While any violation is undesirable, it doesn’t necessarily indicate a serious flaw in the scaffold industry.  And finally, the Top Ten list only indicates the number of citations written, not an accurate count of the citations that ultimately remained and accepted by the employer.  Nor does the list indicate the severity of the violations.  Frankly the only conclusion that can be made is this:  Scaffolding shows up on the OSHA Top Ten list—so what.  The list is meaningless in that it fails to truly indicate the safety or menace of scaffolding.  On the contrary it misleads and thus wastes the efforts of those who are assigned the task of evaluating jobsite safety.  It would be better to not have the list.  Think about it.

OSHA TOP 10 MOST SERIOUS VIOLATIONS

1.     Fall protection  (c)
2.     Hazard communication
3.     Scaffolding  (c)
4.     Respiratory protection
5.     Ladders  (c)
6.     Powered industrial trucks
7.     Lockout/tagout
8.     Wiring methods
9.     Machine guarding
10.  Electrical: systems design

C = Construction standard
Figure 1

Source:  www.osha.gov

Unknown Knowns

By | OSHA Standards & Regulations, Resources, Safety Hazards, Scaffolding | No Comments

It seems that speculation runs rampant at the beginning of every year as forecasters speculate about the economy, markets, jobs, stability and politics. Along those lines, it is time to speculate about the future safety of the scaffold and access industry. More specifically, will scaffolding still rank up there in the OSHA top 10 list of citations at the end of 2015 or will the industry somehow miraculously alter the trend? More importantly, is scaffold safety accurately measured by using the OSHA Top 10 as a reference?

It is generally accepted that OSHA regulations address hazards. Take, for example, the requirement that all extension ladders must extend at least 3 feet (0.9 m) above the upper landing surface. The hazard here is that the worker loses stability while exiting or accessing the ladder. Infractions of this regulation are often cited and consequently show up on the OSHA Top 10 list of citations, suggesting that employees are frequently injured and killed because the ladder doesn’t extend 3 feet above the landing. Since the hazard is a lack of a handhold as the ladder user exits or accesses the ladder, can it be reasonably assumed that the lack of the ladder extension always results in injury or death? Can the correlation be made that the number of citations equals the severity of the hazard? Or is there another explanation that has very little to do with the hazard?

Using the ladder regulation as the example, it is my opinion that the number of citations has more to do with the ease of identifying a violation of a given citation than it is has to do with the severity of the hazard. While it is true that losing your grip while exiting a ladder can result in an injury or even death, it is also true that it is very easy to identify whether a ladder is extending 3 feet above the landing surface or not. In fact you can probably spot this violation while driving down the street. It’s a no-brainer citation. On the other hand, how many citations have been written for a safety factor (29 CFR 1926.451(a)(1) violation where it takes some analysis and calculations to determine if a violation occurred?

The same “no-brainer citation” argument can be used for guardrail systems, particularly on scaffolds. A quick look at a scaffold will determine if the guardrail has been installed. Bingo – another easy citation! This is not to say that fall protection regulations should not be enforced, especially since falls in construction are a leading cause of injuries and death; rather guardrail violations are easy to identify and therefore it is not surprising that guardrail violations consistently show up on citation lists.

Donald Rumsfeld, former U.S. Secretary of Defense said it best: “There are known knowns. There are known unknowns. There are unknown unknowns. But there are also unknown knowns. That is to say, things that you think you know that it turns out you did not.” The secretary’s wise words of wisdom can be applied to the subject at hand. The known known is the number of citations. But wait; there is an unknown known. The number of citations does not necessarily indicate the severity of the hazard but rather the number of citations for a specific regulatory infraction. Frankly, I think it indicates the ease of citation. If a worker falls from a scaffold, it is typically concluded that the lack of fall protection is to blame. But is it? Was the investigation sufficient to warrant such a conclusion? Were the investigators qualified to make such a determination?

Because the OSHA “Top 10 most frequently cited OSHA standards violated” list is commonly used to evaluate the safety of a specific sector of the industry, and because scaffold citations always appear in the Top 10, scaffolding is frequently perceived as a dangerous product in a dangerous industry.   Perception leads to faulty conclusions which of course leads to more faulty conclusions. The Top 10 list can be dangerous if not used properly.

Consider this: Federal and state OSHA has approximately 2,200 inspectors who did 89,664 inspections in 2013. (41 inspections per inspector—not quite one per week on average.) Federal OSHA did 39,228 of those inspections utilizing a budget of $535,246,000.00 to do so, or $13,645.00 per inspection. Are we getting our money’s worth? It is very important that first, citations are accurate and secondly, they stick. That is, the employer agreed to the fine and/or the validity of the citation. Just because a citation was issued doesn’t mean it was a valid citation. Many citations are unwarranted and never result in a fine or agreement by the employer that a violation occurred. Unfortunately this may not show up in the Top 10 List, leading to faulty conclusions.

So, here are the known knowns: Worker deaths have decreased from 38 deaths a day in 1970 to 12 a day in 2012 – that’s good. The bad news is that in construction, 796 workers died in 2013; that means 3 workers in construction died per day! 294 of those deaths were from falls. Here are the unknown knowns: How many falls were from scaffolds? And then there are the unknown unknowns: What were the dead workers doing before they decided to fall to their deaths? Was it a faulty scaffold? Was it an untrained worker? Was it suicide or murder? Was it work related? Was it the employer’s fault? Was it the employee’s fault? Was it a design error (scaffold designer’s fault)? Was it a scaffold supplier error? Or was it an unknown unknown because “things that you think you know that it turns out you did not”? And to think that we know! By the end of 2015, we will know the number of citations (the known known) but will we know the unknown? If history is any indicator, probably not; don’t let statistics be the sole criteria; as the saying goes: “It’s what you don’t know that will kill you.” According to Secretary Rumsfeld, it appears that would be the unknown unknown.

Statistics in this article came from OSHA and can be found at www.osha.gov.

OSHA as Insurance

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Insurance is a big deal.  There’s life insurance, medical insurance, insurance for insurance (reinsurance) and scaffold insurance, to name a few.  Generally, the purpose of insurance is to reduce financial risk for an individual entity; frankly, another way to look at it is that insurance shares the risk with other similar individual entities.  For example, life insurance works for both the insurer and the insured because we don’t all die at the same age.  Scaffold insurance works because not all scaffold companies are having accidents all the time.  Actuaries use data to determine the risks involved for the activity.  If the actuaries get it right, the insurance company makes money and the insureds are protected against disaster.

What if OSHA could be reorganized as an insurance company?  Now, don’t laugh—well not yet anyway.  Let’s see how this might work, using the insurance industry as a model.  Insurance companies evaluate the risk of the activity, determine the cost, and establish a rate to charge the client.  If general liability insurance is the product, the insurance company will look at the costs that companies incur doing business.  For scaffold companies, it will include accidents, lawsuits, injuries and deaths.  Once the risk is established, an adequate premium is determined to make sure the insurance company doesn’t lose any money.  However, taking the same model and applying it to OSHA standards and more importantly, to violations and citations, requires some manipulation and imagination.

Here’s how it would work.  Consider OSHA as the insurance company and the scaffold company as the insured.  Each year a scaffold company would invite OSHA onto any number of its projects for an inspection.  If there are no violations of the applicable OSHA standards, the company would get credit points.  We could call the credit points “OSHA bucks.”  These OSHA bucks would be insurance against future inspections that OSHA does without announcement, like they do today.  A scaffold company could bank these OSHA bucks similar to an insurance policy.  For example, assume a scaffold company has a general liability policy valued at 2 million dollars.  It could similarly bank 2 million OSHA bucks to be used in the future.  If OSHA shows up on a job and finds a violation, the scaffold company would pay the fine with OSHA bucks.

There probably would be a question about how many bucks a scaffold company could get.  Right now the way the system works is that if there is a single violation, the scaffold company wins a citation and gets to pay a hefty fine.  For example, on a scaffold that has a thousand guardrails, if only one guardrail is missing, the company fails the test and is cited.  Therefore, it is only fair that a buck should be given for each component of the scaffold.  If the suspended scaffold has 749 components there are 749 bucks in play.  Conversely, if an investigation of the scaffold reveals that only one component is missing, then OSHA is only entitled to one buck.

Actually, this system could be advantageous to the entire industry.  OSHA bucks could be traded between scaffold companies.  For example, scaffold company A, which constructs really good scaffolds, could trade OSHA bucks for some real money from company B which just can’t seem to build scaffolds correctly.  Contrary to the present system where OSHA can bargain away the monetary value of an impending fine, under this new system OSHA would not be allowed to trade bucks; in fact they wouldn’t have any bucks in their possession for trading.

To make the concept legitimate, there would have to be referees to make sure both the employer (scaffold company) and OSHA were behaving.  The referees would be independent, objective individuals who have a thorough understanding of scaffolding and the standards.  They would be paid by both the scaffold company and OSHA so that there would be no question about fairness.  Alternatively, these referees would be paid by the “loser”, that is, either the scaffold company who does have a violation, or OSHA if there are no violations.

You don’t think this is a good idea?  Here are a few advantages of such a system:

  1. Every time OSHA is invited onto a project, the individual Compliance Safety & Health Officer (CSHO) would learn about correctly constructed scaffolding.  (It’s assumed OSHA wouldn’t be invited onto a jobsite if the scaffold wasn’t correct.);
  2. Scaffold company employees would learn how to construct scaffolds correctly since an inspection is known to be occurring;
  3. CSHO’s would have to know their stuff;
  4. Scaffold companies would have to know their stuff since CSHOs would know their stuff;
  5. Informal hearings, formal hearings, and trials would be abolished;
  6. Ridiculous citations would be eradicated;
  7. Preposterous scaffold company claims would be eliminated;
  8. Resources would be spent on prevention, not enforcement and defense.

Just think how exciting this would be; instead of OSHA being the sheriff, as declared by the Department of Labor several years ago, employers, employees and OSHA would live in harmony since they all would realize that there are some big OSHA bucks at stake.  Of course, the current situation involves some very serious money too.  Unfortunately, it’s the employers that are handing out the money when the citations are unwarranted citations, brought on by inadequate understanding of the standards and scaffolding.  Unfortunately, there is no insurance for that.

Federal OSHA 29 CFR 1926.451(c)(2): Foundations and Swivel Jacks Clarification

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The following is a clarification of OSHA Standard 29 CFR 1926.451(c)(2)(i) which requires that: “Footings shall be level, sound, rigid, and capable of supporting the loaded scaffold without settling or displacement.”

This standard addresses the hazard of a foundation that is insufficient to support the scaffold.  The intent of the standard is to require that scaffold foundations are adequate; that is, they have sufficient strength, are stable, and the footing compensates for non-level surfaces that can introduce horizontal forces which have not been restrained.

The claim has been made that swivel screwjacks cannot be used with scaffolds since they bear on non-level surfaces.  This claim is incorrect since the screwjacks are being used to create the level surface that the standard requires.  While it might be argued that the screwjack is part of the scaffold and consequently must bear on a level surface, this argument is without merit for the simple fact that the swivel screwjack is specifically used for the purpose of bearing on sloped surfaces.

Standards have never precluded the use of swivel jacks with scaffolds.  The truth is quite the opposite: swivel screwjacks are used to create the level surface that is required so that scaffold legs are stable.  Interestingly enough wedges and shims are also used to create a level surface.  By disallowing swivel jacks, it can be argued that wedges and shims cannot be used since they are not part of the foundation but rather are a part of the scaffold.  In other words, if it were not that the scaffold is at a specific location, the wedges and shims would also not be there.

In summary, swivel jacks are a permissible component to be used in the construction of a scaffold.  As with all scaffolds, the scaffold shall be designed by a Qualified Person who will address the issue of horizontal forces when designing the foundation.

OSHA Q & A: Interesting Facts about OSHA

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It’s amazing how many people have very little understanding about the US federal Occupational Safety & Health Administration, OSHA, especially since it has been in existence for almost a half century.  I suspect there are people who still think it’s a town in Wisconsin!  Well, here are some questions, with answers, that might expand, or at least confirm, what you know about OSHA.

When did OSHA become an agency of the US federal government?

A long time ago — 41 years ago.  The Occupational Safety & Health Act was signed into law by President Richard Nixon on December 29, 1970.  This initiated the process that would establish what we know today as the Occupational Safety & Health Administration.

OSHA is part of which governmental department?

OSHA is part of the Department of Labor.

What is OSHA supposed to be doing?

The US Congress determined that too many employees were getting seriously injured and killed while on the job.  So Congress did what they are good at: they passed an act that said employers shouldn’t be killing and maiming employees.  The act became a law when President Nixon signed it.  It’s OSHA’s job to enforce the standards under the assumption that compliance with the standards will result in a safe workplace.

What’s in the Occupational Safety and Health Act?

All sorts of stuff.  The main items can be found in Section 5, parts (a) and (b).  Section 5(a)(1) requires that employers shall provide employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his/her employees.  Section 5(a)(2) requires that employers shall comply with occupational safety and health standards promulgated under the Act.  Section 5(b) specifies that each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to the Act which are applicable to his/her own actions and conduct.  That means as employees, we have to comply with the standards whether we like it or not!

What defines a place of employment that is free from recognized hazards?

The standards that have been promulgated under the act define a safe workplace.

Where did the original standards come from; did someone just make them up?

While it may seem that someone just made them up, the original OSHA standards were derived from existing standards such as the American National Safety Institute, ANSI, standards.  For example, the ANSI A10.8 scaffold standards were used to help develop the scaffold standards.

Do I, as an employee, have to comply with OSHA standards?

Of course you do.  It’s in your best interest and it is required by law.

Why does it seem that employers get cited for violations but employees never do?

Well it certainly isn’t because employees always comply with the standards.  OSHA has determined that it is more effective to go after the employer.  Besides employers are in a better position to pay the fine.

I own my own company and have no employees; does OSHA apply to me?

No.  OSHA only applies to employers and employees.  But don’t get the ingenious idea that you can do whatever you want.  If you are working as a subcontractor under another contractor, it is very likely that you will have to agree to abide by the OSHA standards if you want to do any work.  Besides, you will be affected by the OSHA Multi-employer Worksite Policy.

What the heck is the OSHA Multi-employer Worksite Policy?

It is a policy devised by OSHA to extend the reach of the agency in an attempt to improve safety at the worksite.  (Some folks say that is an overreach of OSHA authority and thus illegal.)  Simply stated, the Multi-employer worksite policy describes the obligations of four categories of employers; first, there is the controlling employer; second, there is the exposing employer; third is the creating employer; fourth there is the correcting employer.  You can obtain more detailed information by going to www.osha.gov, clicking on enforcement, and searching for Multi-employer worksite policy.

Is it easy to change or revise the OSHA standards?

Heck no!  It is a very complex, deliberative process.  And it is meant to be that way.  OSHA cannot arbitrarily change standards any more than you or I.  OSHA, as with other governmental agencies, first develop revised standards, then present them for public input and comment, revise them as necessary, verify the new standards agree with the other standards, confirm that they address hazards appropriately and then finally issue them.  For the revised scaffold standard that went into effect in November, 1996, it was more than a twenty year process.

Is OSHA the authority on scaffolding?

I don’t think so.  They are experts on regulations, the law, and can be experts on the enforcement of the standards.  But it is typically the citizens involved with scaffolding work that are the experts in scaffolding.  That is not to say that OSHA doesn’t have expertise to help develop, write and create standards and other information for employers and employees.  OSHA is a vital link in the chain of knowledge that includes many individuals, companies and organizations with varying areas of expertise that make successful standards.  No single organization or individual has the wealth of knowledge to single-handedly write meaningful standards.

Are OSHA compliance officers trained?

Yes, but based on my experience, nowhere near the level they should be.  This is not a criticism of the individual officer but of the agency.  There is insufficient funding for the knowledge and training that we expect of OSHA compliance officers.  That is why it is so important that we offer our assistance to OSHA to help them understand the business of scaffolding.

Boards and Rails

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A quiz that evaluates your understanding of the correct installation and use of supported scaffold platforms and fall protection.

How well do you know the mandatory standards that dictate how we are to build scaffolds?  Specifically, how well do you know the mandatory standards that counsel us in the proper design and construction of scaffold platforms and fall protection?  Let’s find out!

Here is a quiz to see if you know your stuff.  The answers can be found below.  The first set of questions is “true or false” while the second set is “fill in the blank.”  No cheating on this; try it first from memory and if you don’t get a perfect score see if you can find the correct answer in the federal OSHA standards.  And don’t look at the answers until you are done!

  1. All scaffolds need at least one platform to be a scaffold.
  2. The minimum width platform for a suspended scaffold is 24 inches.
  3. The maximum width platform for a two point suspended scaffold is 48 inches.
  4. A boom lift does not need a guardrail system.
  5. You can guess at the required strength of a fall protection anchor as long as it looks like it can hold 5,000 pounds.
  6. Plank used for a platform can be of any material and strength as long as it can hold four times the intended load.
  7. Aluminum plank cannot be used with steel scaffolding because of galvanic action.
  8. The minimum distance a solid sawn wood plank must overhang its support is 12 inches unless it is secured from movement.
  9. The height of a toprail above a scaffold platform is 42 inches, plus or minus 3 inches.
  10. You must wear personal fall protection equipment and have a guardrail system when working on a multi-point suspended scaffold.
  11. If you are wearing personal fall protection while on a tubular welded frame scaffold platform, you don’t need a guardrail if the platform is no more than 7 feet above the level below.
  12. Same question, different platform height:  If you are wearing personal fall protection while on a tubular welded frame scaffold, you don’t need a guardrail if the platform is no more than 12 feet above the level below.
  13. Toeboards are part of the guardrail system.
  14. If you know you are not going to fall, you don’t need fall protection while on a scaffold.
  15. You have to wear personal fall protection and have a guardrail on a mobile scaffold if you are going to ride it.

Answers to the True and False Questions:  1, True; 2, False; 3, False; 4, False; 5, False; 6, True; 7, False; 8, False; 9, False; 10, False; 11, Trick question—you don’t need fall protection because the platform is less than ten feet above the lower level — True; 12, True; 13, False; 14, Don’t you wish-False; 15, False, but then if you are riding it you like to tempt fate.

Fill inthe blank

  1. The maximum gap between platform units is ___________________ inches.
  2. The minimum toprail strength is ______________________ pounds.
  3. The height at which fall protection is required on scaffolds is _____________ feet.
  4. The minimum overlap for plank is _____________ inches unless the plank is secured from movement.
  5. The minimum width platform on a supported scaffold is _____________inches.
  6. Fall protection for scaffold erectors is determined by the _____________________ competent person.
  7. For a platform on a supported scaffold, the platform shall extend from the front _________________ to the _________________ supports.
  8. Designed personal fall protection anchors must have a safety factor of _____ to one.
  9. Scaffold Platforms shall be designed by a _________________ person.
  10. The maximum space between the edge of the platform to the guardrail system is _________________ inches.
  11. For normal use, if the front edge of the platform is no more than __________ inches from the work surface, it is not considered an open sided edge and does not need fall protection.
  12. The stamp on the side of a scaffold grade plank shall read: ________________________.
  13. If an 8’0’ long plank is not secured, the maximum cantilever past its support is _________inches.
  14. The maximum distance between guardrail posts on a scaffold is ___________ feet.
  15. When you hook off the lanyard of your personal fall protection system to the toprail of a scaffold guardrail system, the rail has to be able to support __________pounds.

Answers to Fill in the Blank questions: 16, one; 17, two hundred; 18, ten; 19, twelve; 20, eighteen; 21, employer’s; 22, uprights, guardrail; 23, two; 24, qualified; 25, nine and one half; 26, fourteen; 27, it shouldn’t read anything– there is no requirement; 28, twelve; 29, trick question—there is no maximum as long as the rails can support 200 pounds; 30, 200—your personal fall protection isn’t being used since you are behind the guardrail, you are just “storing” your hook!

Bricks and Steel

By | Forming, Mast Climber, OSHA Standards & Regulations, Resources, Scaffolding | No Comments

Masons are allowed to be exposed to fall hazards due to over-hand bricklaying while on steel supported scaffolds; the use of side brackets (knee-outs) with supported scaffolds.

It is difficult to imagine masonry construction without scaffolding.  Prior to the advent of steel frame scaffolding, Bricklayer’s Square scaffolding was used to provide an elevated work platform for the masons to conduct their work.  Starting in the 1930’s, steel scaffold frames slowly replaced the wood scaffolds commonly used by masons.  Adjustable scaffolds, specifically designed for masons, became available in the 1970’s and the evolution continues today with mast climbers and other powered platforms being used by masons.

In spite of the variety of the equipment used by masons, several issues have persisted regarding the proper use and safety of scaffolds.  The first issue involves the fall exposure that masons have while constructing a brick wall.  The federal Occupational Safety & Health Administration, OSHA, standards recognize this issue and in 29 CFR 1926.451(g)(1)(vi) specify that “Each employee performing overhand bricklaying operations from a supported scaffold shall be protected from falling from all open sides and ends of the scaffold (except at the side next to the wall being laid) by the use of a personal fall arrest system or guardrail system.”  While clear in its intent, there are still people who do not understand this.  Simply stated, we allow the mason to be exposed to a fall hazard.  That’s right, the mason can fall over the wall if he so chooses.  However, any reasonable mason understands that if he leans over too far, he will fall over the wall!  Typically, masons like to lay brick at waist high which means that the wall acts as the guardrail—problem solved.  In those instances where the wall is lower, then yes, there is a fall hazard.  But the hazard of trying to work through a guardrail system laying brick frankly is a greater hazard.  Please note that only those who are “performing brick laying operations” are allowed to be exposed to the hazard.  In other words, if you aren’t laying brick, you can’t be there.

The second issue involves the use of side and end brackets (commonly, and incorrectly, called outriggers).  The normal use of these brackets is on the front of the scaffold, between the wall being constructed and the scaffold front leg.  These brackets support the plank for the masons and are moved up in convenient increments as the wall increases in height.  There’s nothing wrong with this installation.  The problem is when masons install these brackets on the back of the scaffold and then used them as a landing or storage platform for brick and mortar.  This is not good unless these brackets have been designed for that purpose.  In fact, OSHA addresses this issue in 29 CFR 1926.452(c)(5)(iii) by emphatically stating that these brackets shall be used to support personnel “unless the scaffold has been designed for other loads by a qualified engineer.”  The reason for this is that it is easy to overload the brackets and also easy to tip the scaffold over, nether prospect being very appealing to the mason.  Keep in mind that the standard doesn’t say you cannot do it; if you would like to do it, hire an engineer who can help you.

The third issue that appears on occasion has to do with the material on the scaffold platforms.  There is another OSHA standard, 29 CFR 1926.250(b)(5), that “Materials shall not be stored on scaffolds or runways in excess of supplies needed for immediate operations.”  A quick read of this standard would suggest that a mason could have no more than a few brick or block on the scaffold at any given time.  In fact, OSHA even issued a Letter of Interpretation that stated that all materials had to be removed from the scaffold at the end of the day.  Fortunately, OSHA clarified this letter and stated that the hazards being addressed by this standard included falling objects and scaffold overload.  OSHA concluded that since these potential hazards are specifically addressed in the scaffold standards, while leaving materials stored on a scaffold may be a violation of 29 CFR 1926.250(b)(5) it shall be considered a de minimis violation, one that carries no fines.  Of course it is assumed that the mason will make sure the brick and block will not fall off the scaffold and the scaffold is not overloaded.  This particular issue has appeared recently on jobsites where the Army Corps of Engineers regulations, EM 385, are enforced.  As with all standards, it is important to know what the intent of a particular standard is and what hazard is being addressed.  Once this is understood, it is much easier to resolve any issues regarding the storage of materials.

As long as we have brick and block walls, we’ll have scaffolding.  Scaffolding has proven to be effective and safe, provided you know how to use it safely.  Do you?

Thoughts for a New Year

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

A stimulating and thought provoking discussion addressing safety concerns with scaffolding.

2012 will be an interesting year with the economy, presidential elections, wars, and unemployment weighing heavy on our minds.  In an effort to keep your mind off these depressing subjects, I thought it would be a good idea to focus on what you enjoy—scaffolding!  Well, it beats thinking about the economy tanking and besides, this is a magazine for scaffolding and access.

Have you ever wondered what would happen if everybody was perfect?  Scaffolds would be perfectly constructed and perfectly used by perfectly trained employees.  Now there’s something to think about.  Just think of the ramifications.  No angry jobsite safety monitors; no OSHA citations; no injuries; no deaths.  I wonder what that would do to the unemployment figures.

Why do people like to misuse and abuse scaffold components?  Take knee-outs and brackets as an example.  Why do erectors think knee-outs will support ten tiers of scaffold on top of them and why do users think brackets will hold a mountain of block and brick?

What would happen if we had no OSHA standards?  Would injuries and deaths increase, stay the same, or decrease?  What would the industry do?  What would you do?  Would you do anything differently?  What if there were no compliance officers?  Would it make any difference to your behavior?  Why do we not have one set of standards for the scaffold and access industry in this country?  For example, are the states so unusual that we have to have different standards in California and Michigan?  Why did Washington State rewrite the federal OSHA standards in a “friendly” prose?  Apparently nobody in Washington understood that the standards are not instructions but rather are minimum, enforceable requirements.

Why did the Army Corp of Engineers write a separate scaffold standard somewhat modeled after the federal regulations but yet sufficiently modified so that it is extra confusing?  It would almost seem that scaffolding and physics mutate into strange creatures from state to state and agency to agency.  This could get scary!

Why do we equate longevity with expertise?  You know, just because you have been doing something over and over doesn’t make it right.  And the opposite is true; how can a person fresh out of school be a consultant?  And then we have someone on TV who said: “I’m not stupid you know, I just don’t know stuff.”  Is there a way in 2012 to get scaffold users to know more stuff and increase their expertise?

Why do general safety consultants who have never erected a scaffold think they know more about an erection than a scaffold erector?  Why do some scaffold erectors think they are exempt from the accepted safety practices?  Why is everybody an expert in fall protection and scaffolding?  How can a compliance officer, fresh out of school, understand the 28 subparts of the OSHA Construction Standards?  Why do compliance officers get minimal training in scaffolding?

Why is the American Society of Safety Engineers the secretariat of the ANSI scaffolding standard and not the SIAI?  And here’s something to really ponder:  Has anyone measured the cost/benefit ratio regarding the extensive and some may argue oppressive, government intervention in the scaffold industry?

What will 2012 bring for you?  I wish for you a prosperous, enjoyable year and you experience a year of good health free of injury.