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January 2004

You Don’t Say!

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It’s amazing what is said in the belief that it’s true.  We hear it everyday, everywhere.  Unfortunately, statements are made without substantiation or credible data.  But it doesn’t matter for some people. Say it with conviction and nobody will question the validity, particularly if proof is difficult to obtain.  For example, what if I told you that 40% of scaffold fatalities last year were due to lack of fall protection?  Truth or fiction?  Or conversely, what if I told you that 31% of scaffold fatalities involve suspended scaffolds?  Truth or fiction?  How about if I told you that I have never been killed while working on a scaffold?  Truth or fiction?  Well, let’s see; the third one should be pretty easy to figure out.  If I wrote the article, I must be alive.  But how do you know I wrote the article?  Frankly, you have no idea.  You believe that I have, you have faith in both the editor and I not to mislead you.  However, as the lawyers say, you are assuming facts not in evidence.  I suppose, on the other hand, who cares!  (For the record, I wrote the article.)

What about the first two statements.  They sure sound accurate.  And why would you doubt it?  Sounds reasonable and its in print.  It must be true.  Why would I mislead you, you say.  Would I not check my facts before authoritatively stating a statistic?  Of course I would.  Unfortunately, there are those who don’t.  While an individual may not deliberately mislead you, in any event misleading can still occur.  My experience indicates that this happens frequently when applying safety standards, guidelines and rules.

Put yourself on a construction site, for example, in a discussion with the safety manager for the general contractor or owner.  You have just completed an inspection of your two point suspended scaffold to ensure it is safe and in compliance with the applicable federal Occupational Safety and Health Administration, OSHA, regulations.  The safety manager tells you that your guard rail system is inadequate and that it must be changed.  You challenge his accusation but he insists that OSHA says it must be 42 inches high.  What would you do?  Here’s another example.  Say you have just installed a clamp-on (attachable) ladder to your systems scaffold.  While the ladder ends at the top platform, you have installed hand holds so the scaffold user can access the top platform while hanging on.  An OSHA compliance officer cites you because the ladder doesn’t extend above the platform 36 inches.  Is the compliance officer correct?

In both cases, the assumption is that the safety manager and the compliance officer are correct since both have positions of knowledge and authority.  But wait a minute.  Are they correct?  In a word, no.  But it sure sounds good.  And many times we make changes to accommodate misguided requests because either it’s a lot easier or we just don’t know the accuracy of the requests.

So what it the solution?  First, become knowledgeable.  Receive training, not only in safe scaffold practices, but also in the applicable standards.  Understand job site policies, standards and regulations prior to doing you work.  Understand applicable OSHA standards, whether they are state, provincial or federal.  Once you are knowledgeable, you can then appreciate requests and know if they are fact or fiction, perception or truth.

Second, know your resources.  Do you have a knowledgeable contact person who can give you an accurate answer?  Are you familiar with written resources, such as the OSHA standards, ANSI (American National Standards), Letters of Interpretations, and Directives?  Are you familiar with manufacturers’ recommendations and the Scaffold Industry Association’s Codes of Safe Practices?

Third, don’t make up stuff!  I’m amazed at the creativity of individuals who make up stuff to accommodate their needs.  A good one is the erector who says he doesn’t have to use feasible fall protection because he’s an erector.  Another good one is the general contractor that professes successful 100 % fall protection on the jobsite.  An examination of the federal OSHA standards would indicate that neither claim is accurate.  And that’s the point:  Written standards are the basis for safe behavior.  Procedures are in place to modify those standards, based on consensus, facts, statistics, and an orderly process.  No individual has the right to modify those standards and subsequently declare them to be the standard!  If that were the case, I’d make the rules and you would all have to follow them.

The end result is that standards are developed to ensure that all parties are beginning at the same benchmark.  If you mutually agree to safety improvements on a specific jobsite, that is fine.  Just don’t tell me thats what the regs say.  I want authoritative proof before I’ll agree.  Show me the standard, show me the statistic, show me the Letter of Interpretation, show me the authoritative document.

So are 40% of scaffold fatalities due to lack of fall Protection?  Yes.  Do 31% of scaffold fatalities involve suspended scaffolds?  Yes.  The source is government statistics and the OSHA Training Institute.  Does a suspended scaffold top rail have to be at 42 inches?  I’ll let you figure that out.  Look in the federal OSHA Standards, 29 CFR 1926.451(g) or your state pr provincial standards.  Mark Twain once said that if you tell the truth, you don’t have to remember anything!