Scaffolding Archives | DH Glabe & Associates

Can Scaffolds Support This?

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Spring is in the air, the birds are chirping and scaffolds are being built. Can life get any better? It used to be that contractors feared winter in the northern regions of North America. Cold temperatures, snow, wind and generally miserable conditions prompted owners and contractors to curtail outdoor activities. That was then; now construction charges ahead, fearless and courageous against even the nastiest of weather. Once again science and progress has prevailed! Improved, clothing, materials, equipment and methods allow construction to continue in any environment.

 To facilitate these activities, it was common to enclose supported scaffolds against the weather. But times have changed; cold weather isn’t the only reason to enclose scaffolds. Containment of debris, tools and workers are now common reasons to enclose scaffolds. Enclosures are also used to advertise, block the work activities from pedestrians and even hide the workers who might be gawking at the pedestrians. Enclosing supported scaffolds is now a year around activity in all areas of North America, on all types of projects in all types of conditions.

Unfortunately, workers have false perceptions concerning supported scaffolds that are enclosed, including the perception that the forces on enclosed scaffolds are not as severe in summer as they are in winter; the perception that using open netting results in lower forces than using solid material; that no additional measures must be taken when a scaffold is enclosed and; site conditions have little effect on an enclosed scaffold.

The truth of the matter is that all scaffolds must be designed by a qualified person, that is, someone who can demonstrate the ability to properly design a scaffold, whether it is enclosed or not. Since designing for wind forces is a necessarily complicated matter, it is common that the qualified person for this design work is a Professional Engineer qualified in such activities. Of course, anyone can take a shot at the design (and unfortunately it is often the case), but the results can be fatal due to a gross underestimation of the forces developed by the wind. So, what is so complicated about wind design? Here are a few factors that must be considered:

Wind Forces

It is absolutely true that the force applied to a scaffold and its enclosure from the wind can be calculated. Short of a meteor falling out of the sky, there is no such thing as a “freak act of nature.” Those who argue so because their scaffold fell over need to be retrained. More accurately, an enclosed scaffold can be designed for a certain maximum wind speed; if the wind is expected to be higher than the design speed, either the scaffold must be dismantled, the enclosure removed, or additional measures must be taken to ensure the stability of the scaffold.

Wind Speed

Obviously, the wind velocity (speed) is the main factor in determining wind forces on a scaffold. However, choosing the correct wind speed for a specific location isn’t that easy. Although wind charts have been developed for North America that indicate maximum design wind velocities, choosing the correct velocity is just the starting point. In fact, there are numerous areas of the continent that have “special wind regions” that require additional investigation to determine the expected wind velocity. One example is along the east side of the Rocky Mountain range, extending from Montana down through Colorado and into New Mexico. At certain times of the year, Chinook winds, that is winds that drop down the east slopes of the mountains, reach as high as 100 mph. Similar winds, called the Santa Ana winds, occur in southern California. These winds don’t occur throughout the year; if your enclosed scaffold is erected during the right time of the year you don’t have to design for these winds; but watch out if the job is delayed and the scaffold is still standing when a Chinook wind hits!

Stability Ties

The key to scaffold success is to adequately design the scaffold and its connection to the adjacent structure. While U.S. federal OSHA and other agencies specify the minimum tie requirements for supported scaffolds, the tie spacing most likely will be grossly inadequate for any substantial enclosed scaffold. While #9 or #12 wire may suffice for a connection of an unenclosed scaffold, it typically is never adequate for an enclosed one. In other words, the ties for an enclosed scaffold must be designed for the anticipated tension and compression loads that are expected to occur. For those who choose to wing it and do something such as doubling up the ties should expect to see their scaffold take wing and fly like a kite. Keep in mind that it is not uncommon to have ties (and the adjacent structure) designed to hold several thousand pounds or more.

Adjustment Factors

When a qualified person designs an enclosed scaffold, he or she must consider these factors:

  • The height of the scaffold
  • The geographical location of the scaffold
  • The location of the scaffold relative to the surrounding structures
  • Surrounding Structures
  • Shape of the Scaffold/Structure (e.g. round or square)
  • Local Wind History
  • Partial or Full Enclosure
  • New construction or demolition
  • Existing structures—are the windows open or closed?

Time of year

This is not a complete list but it gives an idea of the potential complexity of the analysis and design.

Enclosure Porosity

Porosity is the fancy word for how many and how big are the holes in your enclosure material. If you are using netting, the holes can be quite small or they can be big. If the holes are over 2 inches in diameter, such as plastic fencing, porosity can be considered. Otherwise, the prudent scaffold designer will consider the netting as a solid material for the simple reason that the holes can become plugged. Snow and ice can easily plug the most porous netting in winter while sawdust, sand, asbestos (why you would use netting to try to contain asbestos is the more important question – you really need retraining!), stucco, plaster and other fine materials will also have an adverse effect on the airiness of your material regardless of the time of year.

While this article doesn’t cover all the factors that must be considered by the qualified person when designing an enclosed scaffold, it offers a glimpse into the complexity of the situation. Merely “doubling up the ties” and “this is the way I have always done it” is not a prudent approach; it just shows you are lucky. And while being lucky may work in craps or roulette, it has no place in the design of an enclosed supported scaffold. Is your life worth a throw of the dice?

This May Interest You

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While some rules and regulations are well known to the industry, sometimes the application of those regulations may be hidden in the complexity of the details. Here are a few confusing questions and equally confusing answers about scaffolding and the applicable standards.

If I construct a stairway utilizing scaffold components, and it is used to access a building under construction, does it have to be inspected prior to each workshift?  No it does not because it is not a scaffold. In this case, the stairway is a construction stairway and must comply with the requirements in 29 CFR 1926, Subpart X – Stairways and Ladders.  There are no requirements in Subpart X that requires the stairway to be inspected before each workshift.

If the stairway is not a scaffold, are the erectors still scaffold erectors.  I don’t know how they can be since they are not erecting a scaffold.

If they aren’t scaffold erectors, what are they?  Good question.  My first guess would be to say they are steel erectors; however, one look at Subpart R, the OSHA steel erection standards, will tell you they didn’t have these guys in mind when the steel erection standards were written.

What if I just follow the scaffold standards regarding erector fall protection?
  That’s probably a good idea although steel connectors don’t have to utilize fall protection until they are up two floors or 30 feet, whichever is less.  That’s a lot less stringent than the scaffold requirements.

You mean to tell me steel erectors don’t have to tie off until 30 feet in the air and scaffold erectors have to at ten feet?  That’s right; just keep in mind that it is the steel connectors (the leading edge guys) that don’t have to tie off.  They have to wear their harness and lanyard at 15 feet but do not have to tie off until two floors or 30 feet.

What if the stairway
was built to access a scaffold?
  The stairway is now a scaffold stairway and Subpart L applies.  Besides other requirements, it has to inspected prior to each workshift.

That’s crazy.  You mean to tell me that I can have one stair accessing a building and it doesn’t need inspection and the identical stair next to it accessing scaffolding needs an inspection prior to each workshift?  You have that correct.  And don’t forget, the first step on the stair ac
cessing the building can be no more than 19 inches while the first step on the stair accessing the scaffold can be as much as 24 inches.

What about trash chutes built inside a scaffold tower—is the tower a scaffold?  It is a scaffold only is there is a platform at the top to throw the trash down the chute.  If there is no platform, it cannot be a scaffold since by definition, a scaffold has to have a platform.

Does that mean the guys erecting the tower are not scaffold erectors?  That’s right.  It’s the same argument that was used for the stairway.

Does the trash chute tower need access?  Why should it—it’s not a scaffold.

Would the trash chute tower have to have a 4 to 1 safety factor?  No—it’s not a scaffold; how many times do I have to tell you?

Are aerial lifts such as boom lifts, mast climbers and scissors lifts considered scaffolds?  Yes, and no.  OSHA included regulations governing aerial platforms in Subpart L where the scaffold standards are.  However, the regulations for aerial lifts are exclusively in section 29 CFR 1926.453 of the subpart, as stated in the Scope and Application of Subpart L (29 CFR 1926.450).

But that section references an American National Standards Institute (ANSI) standard from 1969.  I wasn’t even born then.  Isn’t it outdated?  Of course it is and OSHA recognizes that.  At the end of the aerial lift section there is note that refers the reader to Non-Mandatory Appendix C that lists ANSI standards that are considered to be equal to the requirements of 29 CFR 1926.453.

I heard that OSHA says that a scissors lift is not an aerial platform but rather a mobile scaffold.  Can that be true since ANSI lists a scissors lift as an aerial platform (A92.6) and it shows up in Appendix C of the OSHA standards?  Unfortunately, that is true.  Because of the way the OSHA standards are written, and remembering that it is a legal document more than anything else, OSHA considers scissors lifts as mobile scaffolds and therefore they must comply with the regulations found in 29 CFR 1926.452(w).

That’s stupid, isn’t it?  Not if you understand that OSHA is bound by the way the standards are written.  Of course, we all know that a scissors lift is an aerial platform so buy the ANSI standard from the SAIA and comply with those requirements and you will be safe.  Unfortunately, I have no idea what might happen when OSHA compliance tries to cite you for not locking the casters on your scissors lift!

Do employees have to comply with the OSHA standards? Of course they do.

I thought the employers have to comply and in turn make the employees comply.  It is true that employers must comply with the standards in addition to providing a safe workplace for the employees.  However, Section 5(b) of the Occupational Safety & Health Act requires that employees must also comply.  It’s just that OSHA doesn’t enforce that part of the law.

Why doesn’t OSHA enforce it?  Beats me—why don’t you ask them.  Or better yet, ask your Congressman.

I hear that in Canada they will cite the employee.  That’s true, and even send the perp to jail for manslaughter if he killed someone on the job.

I work on a project that involves the U.S. Army Corps of Engineers.  I have been told that their scaffold standards, referenced as EM-385, are not standards like the OSHA standards but are only part of the contract.  Is that true?  Pretty much so.  And since they are part of the contract that you signed, you have to comply with them.

But they don’t agree with the OSHA standards; now what do I do?  One thought is to get a new job.  This can be tough since you need the cooperation of the compliance officer to make it work.  My suggestion is to use the most stringent regulation.

I am standing behind a guardrail system at the edge of the tenth floor of a building under construction.  The toprail is designed for 200 pounds as required by the OSHA standards.  I am wearing a harness and double lanyard and have hooked off my lanyards to the toprail.  Am I breaking any regulations?  What are you—some kind of trouble maker?  Of course you are not violating any fall protection standards and you know it.  But you sure look good and safe.   And after that question, that’s the last question out of you. (This answer is correct.  Why?)

Suspended Scaffold Q & A

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A suspended scaffold is a marvelous tool for workers to utilize to gain access to work locations that would be difficult if not impossible to otherwise reach. Unfortunately, the general perception is that suspended scaffolds, particularly two point suspended scaffolds such as window washers two point suspended scaffolds, are inherently dangerous and those individuals who use them are similarly inherently dangerous. This is due in no small part to the media exposure that suspended scaffold failures receive. The reality indicates otherwise. Perhaps these questions and answers will help mitigate the fear of suspended scaffolds.

What is a suspended scaffold? A suspended scaffold is a temporary platform that is supported by non-rigid means such as cables, chains or ropes. It is not to be confused with supported scaffolds which are temporary platforms that are supported by rigid means such as legs, posts or frames.

Is a suspended scaffold the same as a hanging scaffold? No. A hanging scaffold is a “temporary work platform without support from below, secured to an overhead structure using fixed length rigid suspension members” while a suspended scaffold utilizes non-rigid suspension members.

In addition to a guardrail system, are users of all suspended scaffolds required to wear personal fall protection equipment? No. A user of a single point or two point suspended scaffold, that is a platform suspended from either one rope or two ropes, must wear personal fall protection equipment properly connected to a lifeline. The reason for this requirement when using a single point suspended scaffold is obvious: if the rope breaks, you are in big trouble if you aren’t wearing a harness connected to a lifeline and anchor. On a two point suspended scaffold, typically only one line breaks, leaving the platform hanging vertically (and making really cool photos for the media) with one worker dangling from his lifeline while the other worker is desperately clinging to the other suspension rope.

Are you telling me that workers utilizing a temporary platform that is supported by four suspension wire ropes don’t have to wear harnesses secured to an adequate anchor?According to most regulations, yes.

That doesn’t sound right—are you messing with me? Nope.

Why doesn’t a multi-point suspended scaffold user have to wear a harness attached to an adequate anchoring system? It is assumed that the platform is sufficiently rigid so that if one suspension rope fails, the platform will remain more or less level and the workers will not slide/fall off the platform. Of course, if your platform lacks the necessary rigidity, you should be utilizing personal fall protection. For example, if you are suspended by three ropes, you probably need to utilize personal fall protection for the unlikely event that you will lose one of your suspenders. On the other hand, if you are on a rigid platform suspended by many suspension lines, such as a suspended platform under a bridge, personal fall protection is probably not warranted. Of course, you must always comply with the qualified scaffold designer’s instructions.

Why do single and two point suspension scaffolds seem to frequently fail? They don’t. If you look at how many suspended scaffolds are used daily in North America, you will find that the failures are insignificant. It’s just that the media likes to report them, You Tube likes to show them and people like to talk about them! (Of course, if you are the worker who experiences a failure, it probably won’t seem insignificant to you.)

Does a cantilever beam used to support the rope that supports an elevated suspended temporary platform have to be designed by a Professional Engineer? Maybe and maybe not.

When is a Professional Engineer required? First of all, the Professional Engineer has to be qualified. That qualified Professional Engineer is required for all multi-point masons suspended scaffolds where the cantilever beams used to support the ropes are secured to the floor. Usually a qualified Professional Engineer is required to design the cantilever beam and rigging, particularly if it is purpose designed for a specific situation. Also keep in mind that many agencies, such as Departments of Transportation, require a qualified Professional Engineer be involved.

Are suspended scaffold erectors required to utilize (wear) personal fall protection equipment? Erectors are expected to utilize personal fall protection equipment when they are exposed to a fall hazard, such as when they are installing rigging on a roof or open sided floor.

Do suspended scaffold users have to have a license/permit to operate a suspended scaffold? Perhaps; it depends on the jurisdiction. Large cities, some counties and state governments require licensing and/or permitting. Before starting any scaffold project, it would be wise to determine the necessary regulatory requirements.

Is a temporary suspended scaffold the same as a permanent suspended scaffold? No. Temporary suspended scaffolds must comply with a different set of regulations and standards than a permanent installation, known as a “PI.” As the names suggest, a temporary suspended scaffold is commonly used in the construction of new structures and intermittent maintenance while a PI is specifically designed for a building, installed permanently on that building, and is intended to be used for providing routine maintenance and renovation.

What appears to be the most common cause of suspended scaffold failures and why? The most apparent cause is lack of training. There are so many safety devices incorporated into temporary suspended scaffold equipment, such as overspeed brakes and extremely high safety factors that it requires ignorance and possibly purposeful stupidity to make them fail.

What is the most important aspect of suspended scaffold utilization?  Training.

Where can I get that training? One good source is the Scaffold & Access Industry Association.

Scaffolding Scores High – Unfortunately!

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

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

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

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

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

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


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

C = Construction standard
Figure 1


Bricks and Steel

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

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

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

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

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

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

Thoughts for a New Year

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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.

How Do They Fit?

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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?

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.

Where Did The Shoring Go?

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

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.