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Safety Hazards

Fall Protection – The Full Package

By | Blog, Fall Protection, OSHA Standards & Regulations, Resources, Safety Hazards | No Comments

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.

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.

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

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

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.

Are Scaffolds That Dangerous?

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

A clarification of the role that wood scaffold plank in the construction of a scaffold platform.

When I tell someone that I work in the construction industry and I design scaffolding, the response is interesting.  If its fellow engineers, they think I’m nuts for working in such a dangerous field.  The liability must be incredibly high.  If I tell a safety person, sympathy is extended due to an obviously difficult career choice.  Tell an accountant and I’m asked how I ever make any money.  Fortunately my mother had always thought it kind of exciting.

But really, can such an activity like scaffolding erection and use be exciting?  Especially since so many people think it is so dangerous?  I can only speak for myself but it is my opinion that it isn’t dangerous and yes, it can be exciting, especially when there is a challenge for access that must be resolved.  Not dangerous you ask?  That’s right; in the overall scheme of life scaffolding is no more dangerous than a lot of other activities.  It’s just that scaffolding appears to be dangerous.  And besides, it’s easy to spot certain deficiencies in an erected scaffold.  You don’t have to be an expert to notice a missing guardrail on a supported scaffold. And you don’t need a doctorate in engineering to ascertain the lack of access.

OSHA consistently issues enough citations to employers each year for scaffold violations that the product of our efforts appears on the Top Ten list year in and year out.  It’s no wonder that the populace thinks we’re crazy with a track record like that.  Is there something sinister going on—perhaps a diabolical industry wide plot to perpetuate the perception of danger in the business of providing access to workers?   I hope not!  Let’s take a look at how the system works.

Scaffolding is a highly regulated business.  Besides federal OSHA standards that dictate minimum behavior, states and even local jurisdictions have regulations that specify how scaffolds are to be erected.  To be sure, the federal OSHA standards are performance standards meaning that the employer and employer have some leeway in achieving compliance with the standards. But that leeway comes with a price.  And herein lies the first problem.  The price for the opportunity to have some flexibility in complying with performance standards is the requirement that the scaffold erector and user must have knowledge about the hazard and the available options to mitigate that hazard.  This also means that the erector must know about the hazard and the applicable regulations in the first place.  In other words, if you want to dance you better know the song.

This brings us to the next problem which is the requirement that erectors, users, evaluators (site safety manager) and compliance officers have an understanding of the intent of the standards.  In fact this may be the biggest problem.  Nobody knows what’s going on!  The erector hasn’t been properly trained and consequently either believes anything a compliance officer tells him or thinks she knows everything.  In any event, everybody starts making up stuff because they don’t know any better.  The compliance officer, on the defensive because he hasn’t been provided adequate training in the subject matter, uses intimidation to make the point.  If that doesn’t work, then threats always seem to win the day.

The next problem is founded in ignorance.  When an individual doesn’t know any better, common sense, openness, a desire to learn and an open mind disappear.  Its replacement is an irrational desire to “win,” no matter the cost.  What a system.

So, how does all this result in scaffolding consistently showing up on OSHA’s Top Ten?  It’s simple: scaffolding is an easy target and we perceive that it is killing people all the time.  Furthermore, it’s an easy citation to write.  Drive down the street, look at a construction project and what do you see?  Yep, it’s a scaffold.  What do you see missing?  Yep, it’s the guardrail.  That’s an easy citation to write.  Let’s see what else I can find.  I remember a regulation that says erectors have to have fall protection and those guys putting up the scaffold aren’t tied off.  I don’t know much about fall protection and I can’t remember the criteria for a correct personal fall protection system but I’ll cite them anyway.  The erectors probably don’t know anything about it either.  That’s an easy citation to write.  Of course, while I’m staring at the scaffold as I drive by, I’m not paying attention to my driving and rear end the car in front of me, injuring the child who isn’t in a child seat or strapped in.  But that’s okay; we accept killing thousands of motorists and injuring many more thousands.  But heaven help the erector who isn’t “tied off.”  I can tell he’s dangerous and the scaffold he is working on is dangerous too.  How can the scaffold not be dangerous?  Just look at all those citations each year.

If we focused on the real hazards on a jobsite instead of the easy fixes, the jobsite would be a much better place.  If we actually trained the compliance officers to the real hazards, the Top Ten would look a lot different.  If we actually trained scaffold users to the real hazards, the Top Ten would look a lot different.  But that takes too much work.  It’s a lot easier to dumb it down.  Of course, the result of that approach is that too many people think scaffolds are dangerous.  And of course, that’s really dumb to think that.

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!

An Association: What is it?

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

This group awarded me the D. Victor Saleeby Award at this year’s convention; I am very grateful for the recognition this award represents and truly regret that I was not able to accept it in person.  I respectfully submit, however, that there are other members of this association who deserve the award more than I.  There are a core of members who have and are continually contributing their time and energy to promote the purpose of this association:  I thank you for this service to the association and because of your service, I accept the award with humility.

What is the purpose of the Scaffold Industry Association?  Amongst other purposes, the association exists “To represent the industry in the development of reasonable product standards and procedures for the maintenance of those standards.”  The volunteers who offer their expertise and time for this cause do so knowing that it will benefit not only themselves, but also their competitors.  Think about this for a minute:  your competitor is helping you.  Is that amazing or what?  Another purpose is “To safeguard and advance the interest of its members by presenting the industry’s viewpoint to appropriate legislative and regulatory bodies and by developing a working relationship with appropriate government agencies.”  That’s right, while you are silently denigrating the compliance officer, your association is working with them.  The alliance with federal OSHA is one such example.  Over the years the association’s members have had a positive effect on the promulgation of standards and rules, not just federal and state safety and health agencies but also the work of the American National Standards Institute.  And you thought that the only thing going on was the yearly convention.

Committee chairmen, council chairmen, committee members and advisors each contribute countless hours of time to the purpose of the association.  The inter-relationship between the various activities creates a synergy that encourages new ideas and concepts.  This is clearly evident in the Training Program.  From its genesis in the mid 1990’s, the program is now recognized as a premier scaffolder training course.  This would not have been possible without the efforts of the individuals and the other committees of the association, especially the support of the SIA Educational Foundation (SIAEF).  Did you know that the SIAEF has applied for a Susan Harwood Grant (The Susan Harwood Training Grant Program provides funds to train employers and employees to recognize, avoid, and prevent safety and health hazards in their workplaces)?  Thanks Mr. McBrayer for your extra special effort!

How can you show your appreciation?  It’s easy—get involved.  Your expertise and experience is required if the association is “To represent the industry.”  This is what it is about:  “an organization of persons having a common interest”.   And when you’re at the next meeting, whether the winter meeting or the summer convention, say thanks to all the members who are working on your behalf.

We Still Have Rules

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

However, recent accidents would indicate that something isn’t quite right.  Maybe the rules aren’t being followed.  Maybe somebody doesn’t know what he/she is doing.  Maybe it’s just plain old bad luck.  I’ll agree with the first two possibilities but most certainly not the third.  Scaffold construction is not a game of chance although some might think otherwise, especially considering recent disasters.

Each time a scaffold failure occurs, there’s a strong possibility that somebody broke a rule.  But it’s not the rule or following the rule that guarantees success.  It is following the principle or action described by the rule that guarantees success.  For example, bracing is required on all scaffolds.  The bracing stabilizes the scaffold and ensures significant strength.  Removing one brace component may or may not adversely affect the scaffold.  If the construction of the scaffold is not understood, that brace may cause a disaster.  Consequently there is a rule that requires that scaffold modification be done only under the supervision of a competent person.  Could the lack of supervision been the cause of recent scaffold accidents?

Not following the rules is a result of either not understanding the rules or choosing not to follow them.  Focusing on the first possibility, not understanding the rules, might be excusable were it not for a rule established in 1970 that every employer and employee must follow the rules, in this particular case, the Occupational Health and Safety (OASHA) Standards.  You, as a user, erector, supplier, manufacturer, or designer,  must know the rules before you get on a scaffold.  No exceptions allowed.  Choosing not to follow the rules, on the other hand, appears to be a sure fire route to disaster.  But is it?  What’s more important, following the letter  of the rule, or theintent of the rule.  No doubt the intent of the rule is the better route.  Unfortunately, to make that determination, you have to understand the purpose of the rule.  To arbitrarily not follow the rule, the minimum standard if you will, makes you directly responsible for your actions.  Are you ready to accept that responsibility?

Unfortunately, many workers view the OSHA Standards as a set of instructions, which they are not; they’re minimum standards, or simply put, rules!  Many workers also think that these rules are optional.  Consequently the unlevel playing field results, the complaints about unfair competition arises, and unequal enforcement of the rules occurs.  But think about it for a minute.  What would happen if their were no rules, no minimum standards for the scaffold industry?  Would you climb a scaffold constructed under those conditions?  Would you still complain about the rules?  I think not.

As an experiment, take a look at the rules for supported scaffolds, a temporary platform supported by rigid supports such as tubes and uprights.  Pick one, any one, and think about the basis for the rule, in other words the intent of that rule.  Does it make sense?  Do you apply the intent of that rule on your scaffolds?  If not, why not?  If so, why?  As an alternative, take a look at the scaffold you are about to use, or erect.  How many rules apply to this specific scaffold?  Could you construct or use this scaffold if it were not complying with any of the rules?  Would you want to use this scaffold if it were not in compliance?  The results of such an inspection might surprise you.  Perhaps the playing field is level after all.

This article was first written and published in 1998, more than 10 years ago.  It is still applicable today, and amazingly – after 10 years – scaffold users are still not complying with the rules!

What Responsibility?

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A very good friend of mine asked me why we always talk about safety from the top down but never from the bottom up.   In other words, why is the focus on management and not the worker?  He suggested that I look into the matter and perhaps offer an explanation or better yet, explain why it is everybody’s responsibility.

My career in the scaffold industry started a couple of years after the federal Occupational Safety and Health Administration, OSHA, started.  I recall at that time that nobody was quite sure what role OSHA was to play in construction and more specifically, the scaffold industry.  Since those days in the early 1970’s much has changed but little has changed.  Scaffolds are still being constructed poorly, employees are getting injured and killed and employers, but not employees, are still being cited.  Why is it that the employers are getting cited and the employee isn’t?  After all, does the law not say that not only the employers are to comply with the OSHA standards but the employee is to comply with the standards also?  That may be a surprise to more than one worker.

Historically, OSHA has pursued the employer over the employee for a number of reasons.  For one, it usually is more effective to go after the employer since he/she has control (it is assumed) over the employee.  Secondly, citing employer/employers on a jobsite and effecting the changes at that level results, supposedly, in more responsible action by everyone on the jobsite.  Third, there may be a political factor that plays a part in who is cited.  (I suspect there isn’t documentation to confirm that.)  Finally, if you are going to fine somebody you might as well go after whoever has the money and chances are the employer has more than the employee.

However, one must wonder if the unbalanced enforcement efforts aren’t producing the detrimental result of discouraging good safety habits by the employee.  Let’s face it: the threat of a fine (loss of beer money) will trump positive encouragement any day.  I’m not saying that we shouldn’t encourage workers to practice, think, and act safely, it’s just that some employees don’t understand anything other than the threat of a fine.  In other words, knowing you won’t get a speeding ticket can have the unintended result of you driving over the speed limit.

This is where the responsibility concept comes into play.  Why is it that some people work safely only when a safety person is watching?  This is the human response, I suppose, but I’m an engineer, not a psychiatrist.  Is it too much to expect a worker to behave responsibly?  Is it too much to expect a worker to accept responsibility for his/her actions?  I think not.  Since responsibility, as described above, means a capacity for being held accountable, it is not unreasonable to expect employees to be held responsible for their own actions.  This is not to say that employers can avoid their responsibility to provide a safe workplace for their employees, as required by the Occupational Safety & Health Act of 1970. But it would seem that a partnership is required between the employer and employee where the responsibilities and rewards are shared.

I don’t think I’m being naïve here.  Unfortunately we do have employers who have not accepted their responsibility as employers.  But for those employers who can show that they have fulfilled their obligation and desire for a safe workplace, then it is incumbent on the employee to accept his/her share of the responsibility for safety.  The employee should not be allowed to shirk a responsibility that can result in self injury.  It just doesn’t make sense to pretend that the employer has that much control that he/she can force the employee to behave.  Frankly, statistics confirm that it hasn’t been possible to do that.  We continually blame the employer, while ignoring the reality that the employee is an essential partner in safety success at the workplace. OSHA has exacerbated the situation by introducing the OSHA “Multi-Employer Work Site Policy (Theory)” so that other employers can be held accountable for the actions of employees.  While there may be some validity for this approach, it still does not hold the culpable employee responsible.

There is no doubt we need an agency like OSHA.  But can you imagine what might happen if the employer, employee, and OSHA worked together to improve safety?  Right now the employer and OSHA are working with each other, but we treat the employee as the orphaned child who lacks the maturity or intelligence to be an adult.  It is time to let the employee grow up and accept responsibility for his/her actions.

Kept in Suspension

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

A review of the standards proves that using a suspended scaffold, such as a two point suspension scaffold typically used for high rise building maintenance and repairs, isn’t any more dangerous than walking down the street that is below it.  In fact, I surmise that a perusal of statistics will show that walking down the street is probably more hazardous than working on a suspended scaffold.  Check out the standards; suspension ropes have to be six times stronger than the load that will be on them.  How can these ropes possibly break?  Obviously somebody is misbehaving.  Is it you?  How well do you know the standards?  Here is a quiz to test your understanding of the federal OSHA standards regarding suspended scaffolds, those scaffold platforms supported by ropes or other non-rigid means.  (Do you suppose the workers who installed the suspended scaffold in the photo would ace this quiz?)

True or False:

  1. The minimum safety factor for suspended scaffold components is 6.
  2. It is permissible to use u-bolts for rope connections supporting workers as long as there are at least three u-bolts.
  3. Outrigger beams can only stick out from the face of the building 24 inches.
  4. Multi-point suspended scaffold users are not required to utilize personal arrest equipment in addition to a guardrail system.
  5. All workers on a multi-level two point suspended scaffold must wear personal fall arrest equipment and be tied off to individual vertical lifelines.
  6. An adjustable scaffold is a suspension scaffold if the mechanical back-up anti-fall dog (level) is inoperable.
  7. All suspended scaffold platform users suspended over water must have life preservers.
  8. All suspended scaffold platform users suspended over water must have at least one lifesaving skiff.
  9. Counterweights for cantilever beams can be water, if frozen, or Jello®.
  10. Counterweights shall not be removed from the beam until the scaffold is disassembled.

Fill in the blank:

  1. All outrigger beams not stabilized by direct connections shall be secured by ________.
  2. When wire rope clips are used on suspension scaffolds, there shall be a minimum number of _________ clips per connection.
  3. Suspension scaffolds shall be inspected before each __________ by a ________ person.
  4. Two point suspension scaffold platforms shall be no more than ________ inches wide unless designed by a qualified person.
  5. The toprail height on a two point suspended scaffold shall be between ______ inches and ________ inches.
  6. The toprail strength on a two point suspended scaffold shall be at least _____ pounds.
  7. All suspended scaffold users shall be trained by a __________ person.
  8. The minimum anchor strength for the personal fall arrest anchor is _______ pounds unless designed by a ___________ person and maintains a safety factor of at least _______.
  9. If an outrigger beam cantilevers 24 inches beyond the fulcrum and the centerline of the counterweight is 12 feet behind the fulcrum, and the load on the suspension rope is 1,000 pounds, the counterweight must be ___________ pounds.
  10. All suspended scaffold installations must be done under the supervision of a _______ person _______ in scaffold erection, using _________and ___________ persons.
  11. Counterweights shall be secured by a _____________ means to the outrigger beam to prevent accidental displacement.

The answers are on page xxxx.  There is no pressure here but remember: you pass if you get all the answers correct and you fail if you get from 1 to 21 wrong; OSHA doesn’t permit partial compliance!

Answers

  1. F
  2. F
  3. F
  4. T
  5. F
  6. T
  7. T
  8. T
  9. F
  10. T
  11. TIEBACKS
  12. 3
  13. WORKSHIFT, COMPETENT
  14. 36
  15. 36 AND 45
  16. 100
  17. QUALIFIED
  18. 5000, QUALIIED
  19. 667 POUNDS
  20. COMPETENT, QUALIFIED, TRAINED, EXPERIENCED
  21. MECHANICAL

 

pic1-kept-in-suspension

That Time of Year

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

It is not a healthy or a safe thing when scaffolds fall over.  Consequently, and not surprisingly, there are codes and standards that address scaffold stability and the minimum expectations regarding scaffold stability.  Both OSHA and ANSI, the American National Standards Institute, have minimum standards for the stability of scaffolds.  Simply stated, scaffolds must be secured to an existing substantial structure to make sure they don’t fall over.  While both agencies specify that the connections, or ties, be spaced no further apart than 26 feet vertically and 30 feet horizontally, (20 feet by 30 for scaffolds 3 feet and narrower), the codes are silent regarding the strength or the expected load on the tie.  In some ways the codes are misleading in that they may imply to the untrained worker that the prescribed spacing is both the minimum and maximumspacing of the ties.  In other words, no matter whether the scaffold is wrapped in an enclosure or not, the spacing remains the same.  Such is not the case!

Scaffolds must be designed by a qualified person, basically an individual who knows what he/she is doing.  If the scaffold is going to be enclosed, the qualified person must be familiar with wind forces, velocity, and environmental effects, in addition to other factors.  Where the scaffold is located, the shape of the scaffold, the shape of the structure, whether you are in Chattanooga or Casper, the height of the scaffold, if the windows are open or not, if the scaffold is in the city center or suburbs, and the height of the structure and the scaffold, are all factors that must be considered.  This is not time for guesswork and yet that is exactly what occurs.

One classic approach is to “double up the ties.”  Fortunately this works for a lot of scaffolds, not because it is accurate but because the scaffold erector is lucky.  That’s right, lucky.  Believe it or not, the force on the scaffold can be accurately calculated.  Much research has been conducted by engineers to determine the force of the wind on structures.  Several years ago a horrific accident occurred inChicagowhere a suspended scaffold failed and fell to the street, killing innocent people.  The ensuing investigation determined the vertical force on the scaffold due to the wind was over 11,000 pounds!  This is serious stuff and yes, the forces can be calculated.

Lucky for the scaffold industry, compliance and safety workers generally cannot determine the forces on a wrapped scaffold and consequently cannot determine if an enclosed scaffold is at risk or not.  But this is changing.

pic16-that-time-of-year

Figure 1 illustrates a scaffold at the Air Force Academy that was wrapped.  That area ofColoradocan experience high winds, in excess of 100 mph.  That’s like a Category 2 hurricane.  Is it possible to design a scaffold that can resist this kind of wind?  Sure—look at Figure 1.  Was this scaffold designed on the fly by doubling up the ties and hoping for the best?  No, it was designed by a qualified person, who appropriately applied engineering principles that resulted in a safe design and successful installation.  The bottom line:  Comply with the applicable standards and good construction practice:  Have a qualified person design the scaffold and construct the scaffold according to that design.  (How about that, there are ANSI and OSHA standards that say exactly that.)  So, how much force does the wind exert?

clip_image0021-that-time-of-year

Figure 2 shows an example of the types of forces that can be expected.  Note how the pressure increases dramatically as the wind speed increases.  In other words, at low wind speeds there isn’t much load on the scaffold but as the wind velocity increases, the pressure or force increases much faster.  Notice what happens at 90 mph.  Based on a tie spacing of 26 feet by 30 feet, the load on that tie is 1,625 pounds for an open scaffold but when it is enclosed, that load goes to 22,000 pounds.  That cheap eyebolt you’re using to hold that wire tie just isn’t going to fare well.  You may say that you don’t get 90 mph winds.  While that may be true, you can easily get 50 mph wind gusts and of course, you only need one gust to ruin your day.

What about the second issue, the issue where OSHA considers the enclosure installation as not being a part of the scaffold erection?  This is a sensitive issue.  Basically, OSHA is claiming that the enclosure is not a structural part of the scaffold and thus is not part of the scaffold erection.  Therefore, fall protection, either a guardrail system or personal fall protection system, is required for the enclosure installers; the OSHA Subpart L fall protection standards, 29 CFR 1926.451(g) apply.  However, OSHA chooses to ignore the fact that if a structure is erected solely for the purpose of supporting an enclosure, it is not a scaffold in spite of the fact that scaffold components are used to support the enclosure.  By definition, a scaffold is a temporary elevated platform and it’s supporting structure, used to support workers or materials or both.  If there is no elevated platform, there is no scaffold; the structure is a structure.  OSHA Subpart M would apply in this case.  What do we do?  Stay tuned, we’re working on it.