Posts Tagged ‘OSHA’

Tarps and other enclosure materials, such as plastic sheeting, are typical materials used to create a desirable work atmosphere.  Many scaffolds are enclosed in screening and debris netting—I recall one resort project in Aruba where the scaffold was wrapped in a mesh to ensure, so I was told, that construction debris would not blow into the adjacent swimming pool.  In reality it was there so the guests below couldn’t see the less than productive construction workers staring at them!  And, of course, now that outdoor temperatures in North America are slowly falling, thoughts of a cozy work environment on a supported scaffold become more frequent, resulting in more scaffolds being wrapped in some type of enclosure so that work can continue.  It is interesting that wrapped scaffolding has been frequently discussed and written about and yet each year scaffolds fall over because somebody wrapped the scaffold without giving much thought to the effects that the enclosure would have on the stability of the scaffold.  Of course, one of the keys to a successfully constructed scaffold is making sure that the scaffold doesn’t fall over; this is especially important for the individuals who happen to be using the scaffold!

The concept of stability is straightforward:  The forces that want to knock the scaffold over have to be resisted.  How can this be done?  While there may be a number of methods that can be used, there are three that are most commonly used by scaffolding designers and erectors:: tying the scaffold to another strong structure that can resist the forces; guying the scaffold tower to a suitable anchor that can resist the forces, and; making the scaffold large enough so the size and weight of the scaffold are adequate to keep the scaffold from falling over.  Since the stability of a supported scaffold is desirable, standards and regulations have been written to address the issue.  The U.S. Federal Occupational Safety & Health Administration, OSHA, requires that “Supported scaffolds with a height to base width ratio of more than four to one (4:1) shall be restrained from tipping by guying, tying, bracing, or equivalent means….” [29 CFR 1926.451(c)(1)]  The standard goes on to require that when the scaffold is tied to an existing structure, it has to be tied at a frequency of no more than 30 feet horizontally and 26 feet vertically for scaffolds wider than 3 feet, and 20 feet vertically for scaffolds 3 feet and narrower.  (In California the requirements are more restrictive.)

Unfortunately, this regulation can be very misleading for the simple reason that it doesn’t address varying field conditions.  Keeping in mind that the OSHA scaffolding standards are minimum requirements and not directions or instructions, the qualified person who designs the scaffold shall determine the proper means and methods for ensuring the stability of a scaffold.  Also keep in mind that a qualified person will not guess at what is required to ensure scaffold stability.  Unfortunately, the reality is that too many scaffold erectors and users think that experience is a great method for determining what it will take to keep the scaffold from falling over.  While the OSHA mandated requirements may work for a scaffold not wrapped in plastic, the same tying requirements will be woefully inadequate for a scaffold wrapped in a tarp and subjected to a violent winter storm.  (Lucky for many wrappers, the enclosure material rips into pieces and blows off before the scaffold is yanked from its’ moorings!)  When a scaffold is wrapped in a quality enclosure, that is a netting or enclosure that is resistant to tearing, the scaffold instead will rip, bend and ultimately fail.

Interestingly, #9 wire is often used to secure a scaffold to a structure.  While this can work with an open scaffold design, it very rarely is adequate for a wrapped scaffold, even if the ties are “doubled up.”  Remember, guessing never has worked well as a substitution for a properly designed and erected scaffold.

So, what is the worker to do?  The answer is easy, logical, and in compliance with the applicable standards and good scaffolding engineering practice.  Have a Qualified Person design the scaffold.  In the case of a wrapped/enclosed scaffold, it will probably take the skills and expertise of a Qualified Professional Engineer who can design the scaffold for the anticipated forces at the specific scaffold location and for the specific time of year that the scaffold will be exposed to external forces from the wind and other environmental conditions.

If you think that you are qualified to design an enclosed scaffold answer yes or no to these statements.  (If you answer no to any of them, you are not qualified to design an enclosed scaffold):

I know where to find the information that tells me what the design wind loads are for my scaffold location;

I am familiar with the American Society of Civil Engineers (ASCE) Standard, Minimum Design Loads for Buildings and Other Structures wind loading criteria;

I know the strength of #9 wire and why it shouldn’t be used for wrapped scaffolds;

I can calculate the forces that are a result of a 100 mph breeze;

I know how to calculate overturning moments and forces due to pressures;

I know what the effects of a partially wrapped scaffold are;

I know what happens if the windows are open;

I know what effects a building corner or roof has on a wrapped scaffold;

I know my limitations.

DH Glabe & Associates (DHG) has recently completed Fall Protection Analysis and Façade Access Certification at the Lockheed Martin Facility in Littleton, CO. The facility has 1600 lineal feet of a monorail suspended access system which is utilized for façade access and window washing operations. EMCOR Facilities Services contracted with DHG to complete the assessment to comply with OSHA, ANSI, ASME  and IWCA standards. Specifically, the general regulations referenced were OSHA 29-CFR-1910, IWCAI-14.1, ANSI Z359 & A10.8, and ASME A120.1.

The façade access certification was performed by loading the monorail suspended access system to twice its rated capacity to verify the integrity of the system. To do this, DHG engineers designed a purpose built cart to accommodate the various terrains around the perimeter of the building.  The cart was then loaded with the appropriate amount of counterweights and suspended from the system.

DHG also provided a structural analysis to validate portions of the existing building to be utilized as bearing points for temporary anchors for fall protection.  This was performed using a computer modeled analysis of the parapet wall and accounted for the personal fall arrest system that is to be worn by the contractors employees during window washing operations.

Connections play a big part in the proper erection of a scaffold. Knowing how connections work, which products to use, and their strengths are important for both erectors and users.

Being well-connected may suggest that you have a strong bond with another person or at least you may have influence over another person’s behavior and action. Unfortunately, this article is not about that type of connection-you’ll have to go somewhere else for advice on being personally well-connected. But what about your scaffold; is your scaffold well connected? And what kind of connections are we talking about?

There are all kinds of connections found in scaffolding. In engineering terms, there are shear connections, tension connections, compression connections, moment connections, and bearing connections. These connections can be provided by bolts, nails, screws, wire, welds, glue, adhesives, tape, bubble gum, string, wire rope, friction devices, u-bolts, swaged fittings, fist-grips, expansion anchors, coupling pins, retainer pins, studs, rivets and bungee cords. Well bubble gum might be a reach but the rest are legitimate; the choice of connection depends on the required strength of the connection and the application. For example, using string to attach a frame scaffold to a building will only provide a tension tie (it works only for pulling, not pushing) and the string probably does not have the required strength. On the other hand, you could weld the same scaffold to the structure but then the weld would have to be cut when the scaffold is dismantled-probably not a good choice for this application.

Myths are pervasive in the scaffold business and often include connections. Can wire, specifically # 9, 10 or 12 gauge wire be used for connections? Do we need high strength bolts for everything scaffold related? Can I use duct tape? Are friction connections bad? And can I hang a supported scaffold by its coupling pin? The easy answers, in order, are: Maybe, maybe, doubtful, no, and perhaps.

Let’s start by looking at the issue surrounding the use of wire. Wire is often used to provide a connection between a supported scaffold and a structure to provide stability so the scaffold doesn’t fall over. While the federal Occupational Safety & Health Administration, OSHA, specifies that supported scaffolds be tied to a structure at certain intervals, it does not specify the strength. Therefore, anything can be used, including wire, string and duct tape, provided it is sufficiently strong. On the other hand, California OSHA, (CalOSHA), allows the use of #10 or double wrapped #12 wire to connect the scaffold to the structure. This is an interesting concept since it assumes that these size wires are adequately strong regardless of the circumstances; this is a bad approach since wrapping the scaffold with enclosure material will probably overload the wire connection. In another common application, scaffolders frequently want to secure a scaffold leg to a coupling pin using #9 wire in place of a retainer pin. This could be a bad idea since the wire may not be able to handle the shear (karate chop) load.

Clamps/couplers are commonly used with supported scaffolds, providing a rigid or swivel connection between two tubes. The clamps primarily rely on friction to provide the connection and there are those (whoever those are) that say this is bad—you should never rely on friction for the connection. They (whoever “they” are) apparently don’t realize that they (same folks) rely on friction to walk, drive, stop, sit, or eat. In spite of the “friction myth,” scaffold clamps work because trained scaffold erectors understand that the clamp has to be properly tightened to ensure a proper connection.

And what about the myth of high strength bolts? I have no idea where this myth started but for some reason everyone (whoever “everyone” is) thinks that only high strength bolts can be used for scaffold connections. Sure, if a high strength bolt is used as a connection on an aerial lift, for example, then you better replace it with the correct high strength bolt. But, come on, regular everyday bolts work for many applications. If you want to use high strength bolts everywhere that’s fine with me; just don’t tell me it’s required.
And what about that coupling pin/connector that aligns one scaffold leg on top of another? Since its primary purpose is to provide alignment what strength is required? Well, it doesn’t have to be very strong unless you decide you want to hang your scaffold (as opposed to suspending a scaffold from a rope). Now the coupling pin must have sufficient strength to hold up the entire scaffold that’s hanging. Usually the coupling pin isn’t strong enough. And guess what– the bolts have to be strong enough too. May I suggest having a qualified person design that connection before you kill someone? By the way, don’t necessarily rely on the manufacturer; he/she may have no idea what to tell you.

As for those funny little connectors that secure a suspended scaffold wire rope to an anchor, its best to make sure that they are installed correctly. These connectors, whether u-bolts, fist grips, or swaged fittings, they all rely on friction. In this case, definitely follow the manufacturer’s recommendations for torque specifications since this is the key to safe use. And, don’t forget that the correct size and quantity of u-bolts or fist grips are required.

That brings us to the use of duct tape. Applicable standards and good engineering practice dictate that all connections must have adequate strength to support 4 times the anticipated load. If you can tell me the strength of duct tape in tension, I’ll be happy to design a suspended scaffold for your use. Will it be a single point or two point suspended scaffold platform that you want? Oh wait, I forgot that you want to go up and down with suspended scaffold. I think the hoist is going to be a tricky one to design! Perhaps we should stick (no pun intended) to something a little more conventional.

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.

A practical explanation as to the relationship between the OSHA standards, enforcement, compliance and safety in the construction industry.

It’s been a long time since I first became involved in the business of scaffolding.  My experience has included a lot of scaffolds, a lot of places and a lot of people.  It has also included a lot of regulations.  As a blossoming young engineer, I still recall asking by boss how OSHA fit into the design of scaffolding.  Since federal OSHA was just a couple of years old at that time, he responded with a clearly stated:  “I don’t know.”  Forty years later, it appears that we still don’t know how OSHA fits into the design, construction and use of scaffolding.   To be fair to federal OSHA, it doesn’t appear that any regulations, standards, codes or guidelines fit into the design of scaffolding.  Now, before you get yourself all wound up, this may be somewhat of an extremely broad statement.  But think about this:  We have standards regarding fall protection and more specifically guardrail systems.  In my research I have found guidelines regarding guardrails going back to the 1920’s, almost a century ago.  And we still have people designing, constructing and using scaffolds without fall protection.  If nothing else, we have consistency.

So what’s the problem?  Is it poor enforcement?  Is it poor training?  Is it poor knowledge?  Is it ignorance?  Or maybe we just don’t care.  Being a Professional Engineer, and accepting the responsibilities that go with the privilege, I am obligated to comply with the myriad of regulations, standards and codes that apply to the profession.  Not to do so will result in the loss of my license and opportunity to earn a living.  I don’t state this because I think I am special, but rather qualified professionals (degreed and licensed or not) accept the obligation that is or should be expected in the business.  I don’t agree with all the regulations; for that matter I’m not really keen on any of the regulations—it certainly stifles constructive creativity.  In fact, regulations are insidiously invading all aspects of our lives, resulting not only in a dumbing down of the industry but also in an erosion of expertise, efficiency, economy, and productivity.

Of course, those tasked with the enforcement of these regulations smugly point to the results of their policing actions.  They publish yearly results of their efforts as if those efforts have any real effect on the industry.  Frankly, the annual OSHA list of the top 10 violations has no relation to the degree of danger involved in the infraction.  For example, scaffolds always show up in the top ten, suggesting that there is a real problem with safety in the industry.  But is there a problem?  Perhaps scaffolding shows up so frequently because infractions are easy to spot and the compliance officers haven’t been trained to evaluate where the real hazards are.

One of the favorite activities these days is the harassment of professional scaffold erectors (casual erectors, where the problems really occur, seem to be immune.)  Statistics indicate that the death rate of professional erectors is extremely low, particularly when compared to the 80 annual deaths that occur with scaffold usage, the deaths in construction and more dramatically when compared with the approximately 37,000 people killed on the highways each year.

The situation is becoming so ridiculous due to what I think is a growing hysteria about safety and the lack of understanding of the actual hazards.  Enormous amounts of time and energy are uselessly spent deciding whether a regulation has been violated instead of investing in the safe productive work that should be happening.  How many times have you sat in a meeting ascertaining whether there is compliance with the regulations?  How many hours have been wasted bickering about the nuance of a regulation instead of determining how to get the work done safely?

I am not advocating the abolishment of enforcement but something has to change.  It is absolutely amazing how people think they are experts in erector fall protection, for example, and yet have never erected a scaffold in their lives.  And yet we give them the authority and take it away from the people most affected.  Furthermore, it is stunning to me how many government agencies, construction industry organizations, unions and engineering committees feel compelled to propagate more and more regulations, many applying to scaffolding, and yet do not even bother contacting the Scaffold and Access Industry Association or the Scaffold Shoring and Forming Institute for input.  Are you aware that the American Society of Civil Engineers has a code regarding construction loads which includes specifications for scaffold loading?  I didn’t think so.

I can sure complain about the problem but unfortunately I don’t have a snappy quick solution.  We cannot abolish decent standards and codes nor can we abolish enforcement—those are needed for those employers and employees who just don’t get it.  But we do need to abolish the politics in safety.  Have you ever wondered why we chase after the employer but not the employee?  Me too.  Have you ever wondered why compliance officers don’t receive sufficient training for the task at hand?  Me too.  Have you ever wondered why so many designers and constructors erect scaffolds without having any clue as to what a safe scaffold is?  Me too.  Have you ever wondered why we allow the sale of scaffolding in this country without any idea of its load capacity?  Me too.  Have you ever wondered why safety consultants have such a poor understanding of the true hazards in scaffolding?  Me too.

Forty years ago we were killing and maiming scaffold users.  We’re stilling doing it today.  And I still don’t know how OSHA fits into the safe design of scaffolding.  However, I do know what a safe scaffold is.  Do you?

An appraisal of the codes and standards that apply to aerial lifts, including boom lifts and scissors lifts.

Sometimes it’s simple, sometimes it isn’t.  When it comes to aerial platforms, such as boom lifts, scissors lifts, mast climbers and the like, the applicable OSHA standards get twisted, misapplied, and misused.  What causes this, you ask?  Well, maybe you don’t ask, but here it is anyway!

First a little history:  When OSHA decided to revise the Construction Industry scaffold standards, it was determined that aerial platforms (OSHA calls them aerial lifts), would be included.  Since aerial platforms are a very specific type of scaffold, OSHA acknowledges this fact by clearly stating in the Scope and Application [29 CFR 1926.450(2)] that “The criteria for aerial lifts are set out exclusively in §1926.453 of this subpart.” To further emphasize this exclusivity OSHA restates the obvious in the General Requirements, §1926.451, stating that “This section does not apply to aerial lifts, the criteria for which are set out exclusively in §1926.453.” What all this means is that none of the scaffold general requirements, including fall protection, access, platforms, and falling object protection to name a few, apply to aerial platforms.

In theory, for aerial platforms, all of this information is contained in §1926.453.  And this, in my opinion, is where the confusion begins.  §1926.453 references an American National Standards Institute standard, ANSI A92.2-1969.  Furthermore, OSHA describes the equipment it considers to be an aerial lift:

(i)                 Extensible boom platforms;

(ii)               Aerial ladders;

(iii)             Articulating boom platforms;

(iv)             Vertical towers; and

(v)               Any combination of any such devices.

The 1969 in the standard is the year 1969.  This was the current standard when the scaffold standards review began.  Consequently this is the standard that was used to establish the definition for an aerial lift.  And therein lays the problem since there has been a substantial growth of aerial platform types since 1969.  Fortunately OSHA recognized that new types of aerial platform equipment and ANSI standards have been introduced into the market since 1969. A note was added at the end of §1926.453 in the OSHA standards that recognizes the ineffective applicability of the 1969 ANSI standard by referring the reader to Non-mandatory Appendix C which “lists examples of national consensus standards that are considered to provide employee protection equivalent to that provided through the application of ANSI A92.2-1969, where appropriate.”  Non-mandatory Appendix C lists ANSI A92 Consensus Standards which apply to the aerial platforms that are familiar and common today.  Included in this list are familiar aerial platforms such as “Boom Supported Elevating Work Platforms” and “Mast Climbing Platforms.”

In practical terms, the referenced ANSI A92 standards are the best resources to use to ensure safe use of aerial platforms.  In fact, a review of OSHA §1926.453 will quickly illustrate the deficiencies of OSHA §1926.453.  This is said not to criticize the OSHA standards but rather is a statement of fact concerning the limitations of the OSHA standards regarding aerial platforms and the legal restraints that often stifle standards writers’ efforts.  The ramification of all this is confusion!  Interestingly, the scaffold General Requirements, §1926.451, are frequently cited as applicable to aerial platforms.  This is incorrect although common practice would indicate otherwise.  Additionally, OSHA §1926.452, Additional Requirements Applicable to Specific Types of Scaffolds, does not apply since aerial platforms are “exclusively set out in §1926.453.”   Clear to me; clear to you?

In legal or perhaps technical terms the outcome of standards application is a bit different.  This shows up in an OSHA Letter of Interpretation that opines that “Self Propelled Elevating Work Platforms” (ANSI A92.6), commonly known as scissors lifts, are not aerial platforms/lifts but rather “Mobile Scaffolds.”  Due to the constraints and wording of the language in §1926.453 and the ANSI A92.2-1969 standard, it is argued that scissors lifts are not included in the ANSI A92.2-1969 standard.  Thus, scissors lifts are not aerial platforms/lifts.  If they are not aerial platforms/lifts, they must be something else.  I guess since a scissors lift has an elevated platform and it has wheels, it can be concluded that scissors lifts are rolling scaffold towers.  Using this logic, helicopters, airplanes, forklifts, Airline Ground Support Vehicle-Mounted Vertical Lift Devices (ANSI A92-7), and boat trailers can be considered rolling scaffold towers!

What’s the bottom line?  The scaffold General Requirements do not apply to aerial platforms.  The scaffold Additional Requirements Applicable to Specific Types of Scaffolds  do not apply to aerial platforms.  In spite of OSHA’s opinion that scissors lifts are Mobile Scaffolds, scissors lifts are aerial platforms.  After all, I would think the industry should know what their equipment is; I hope you agree.

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.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

An April Fools Day sarcasm on scaffold safety, regulations and government control.

April is the time for foolish things so I contacted the foremost authority in the field of scaffolding, Dr. Aiy Noitall.  I caught up with the good doctor while he was at O’Hare Airport in Chicago preparing to leave on another of his famous fact finding missions for the government.  Here is an excerpt from an intense 87 minute interview I had with him before he boarded his flight.

SIA:  Dr. Noitall, you are recognized as an expert in the field of scaffold safety.  How did that come about?

Dr. A. Noitall (Dr. A.N.):  Well, you know that I have been hanging around scaffolding all my life; well at least I see a lot of it so I picked up a lot of stuff that way.  Besides, since I am sponsored by the government program, I know some of the standards.

SIA: You mentioned the government program.  What program is that?

Dr. A.N.: It’s a program funded by a bipartisan quasi select government action committee on largesse.  The committee has initiated a fee on all employers who use, sell, rent or design scaffold products.  That’s how we get the funding.

SIA:  That’s odd.  As you know the Scaffold Industry Association is the “Voice of the Scaffold and Access Industry.”  We haven’t heard of this committee or the program.  And we are unaware that there is a fee; that sounds like a tax.  Who authorized this?

Dr. A.N.: Well, the government authorized it.  Trust me; just like the OSHA standards, Canadian standards and various state and provincial safety standards, this program is good for you.  I always say, you can’t have too many safety regulations.  This is how we make things safe.

SIA:  I thought it was employees and employers who make a worksite safe.

Dr. A.N.: See, that’s where you have it wrong.  Scaffold people don’t know what they are doing.  They’re out there trying to kill people.  The statistics show that.  If it weren’t for the regulations, all the scaffold people would be dead!

SIA:  Well, the SIA wouldn’t agree with that!  Let’s look at a few of those regulations.  What do you think of the rule that specifies that guardrails are required once the platform is ten feet off the ground?

Dr. A.N.: That is nonsense.  I think the height should be 10 inches.  We can’t provide enough protection for the worker.

SIA: Don’t you think the worker has a responsibility to work safely?

Dr. A.N.: Well, there is no need for the worker to worry about that safety stuff.  We want him to be focused on his work, not safety.   That’s why we need a lot of regulations.  If we can get to the point where there are so many regulations that the worker doesn’t have to think, then my job is done!

SIA:  Wow, that is quite the energetic agenda.  When do you think you’ll reach the point of enough regulations?

Dr. A.N.: My extensive research indicates that we will probably never get there. If you look at the OSHA statistics, you’ll see that scaffolding is always in the top 10 violations.  That clearly shows I still have a lot of work to do.

SIA:  Let’s take a look at another regulation.  As you know, or should know, boom-lift operators are required to have fall restraint whenever operating that equipment.  Yet, it’s easy to find operators who either don’t know or don’t care about that requirement.  How will more regulations solve that problem?

Dr. A.N.: You just don’t get it, do you?  The hazard, as you know, is being catapulted out of the boom lift.  If the worker utilizes fall restraint or fall protection how can he do his work?  It’s better to have regulations to solve the problem.  Besides, if he is hanging on, he won’t get catapulted off the platform in the first place.

SIA:  You aren’t making any sense sir.  More regulations won’t eliminate the possibility of the worker being ejected.  Please explain, if you can.

Dr. A.N.: Let me give you an example.  Scissors lifts had guardrails around them supposedly for protection against falls.  However, when the workers used the guardrails to stand on, they discovered that the guardrails wouldn’t keep them from falling.  So now we require them to use personal fall restraint or fall arrest.  See, this is how more regulations work.  I just don’t understand why you think they don’t.

SIA:  That doesn’t answer the question about ejection.  You didn’t answer my question.

Dr. A.N.:  Sure I did.  You weren’t listening.

SIA:  Whatever.  Let’s take one more example and see if you can convince me that more regulations are the answer to safety.  The OSHA standards require that a platform be “fully planked between the front uprights and the guardrail system.”  What happens if the platform is only 2 feet off the ground and there is no guardrail system?  How big should the platform be?

Dr. A.N.: I can’t believe you even bother to ask me this question.  The platform should be as big as you can make it so the worker is free to do whatever she wants.  If it’s big enough, the worker will never fall off the edge, will she?  See, that’s what I’m getting at— more is always better.  It would be foolish to think otherwise.

SIA:  Foolish indeed, Dr. Aiy Noitall.  Enjoy your flight—and good luck getting through airport security.