Experience indicates that certain scaffold safety issues remain unresolved in the minds of those responsible for safety. More specifically, it appears that fall protection requirements and access requirements are not understood. So, let’s see if we can sort out the issues.
Fall protection for scaffold users is addressed specifically, and exclusively, in Subpart L of the Occupational Safety and Health Administration, OSHA, Construction Standards while fall protection for “walking/working surfaces” is addressed in Subpart M of the OSHA standards. What’s the difference? By definition, a scaffold is “any temporary platform and its supporting structure used to support workers or materials or both.” On the other hand, a walking/working surface means “any surface, whether horizontal or vertical, on which an employee walks or works.” The significance of all this is that each subpart has a different height threshold when fall protection is required. Scaffold platforms require fall protection once the platform is ten feet or more above the level below. For walking/working surfaces, the height is six feet. There should be no dispute here since the regulations are very clear in this regard. Subpart M frankly states that scaffolds are excluded (29 CFR 1926.500(a)(2)(i)). This should be pretty easy to figure out. Unfortunately there are those who like to believe what isn’t true!
To summarize the issue of fall protection, Subpart L applies to scaffolds, not Subpart M. Therefore, the height threshold is 10 feet, not 6 feet. The only exception occurs when using personal fall protection. In that case, the anchor strength and freefall distances of Subpart M apply, nothing else. If guardrails are being used for fall protection on a scaffold, then nothing in Subpart M applies. It’s that simple.
Access is another area where confusion reigns for those who do not fully grasp the relationship between the various subparts of the OSHA standards. The confusion centers on the use of ladders with scaffolds. Those unfamiliar with the standards assume that clamp-on ladders are fixed ladders. Nothing could be more inaccurate. The scaffold standards clearly spell out thatportable ladders shall comply with the applicable portions of the ladder standards, Subpart X of the OSHA Construction Standards. This does not include clamp-on ladders. Sure, clamp-on ladders are vertical, just like fixed ladders. But that’s pretty much where the similarities end. As a matter of fact, there’s simply no way that the fixed ladder standards can apply to ladders used with scaffolds. OSHA understands that. In fact, OSHA has clarified this issue by issuing a letter of interpretation that explicitly excludes scaffold clamp-on ladders from the fixed ladder standards.
To summarize, the scaffold standards apply when using clamp-on ladders on scaffolds. It is true that when using portable ladders, such as extension ladders, certain Subpart X ladder standards apply. In that case standards addressing strength and dimensional requirements apply, as well as the standards addressing the use of portable ladders. (These regulations address important aspects of ladder usage such as positioning of the ladder, extension of the ladder above the platform, and using three point contact while climbing the ladder.)
To wrap it up, all this information is readily available. The regulation that excludes scaffolds in Subpart M (Fall Protection), can be found at 29 CFR 1926.500(a)(2)(i). The scaffold fall protection requirements can be found at 29 CFR 1926.451(g). The requirements that apply to the use of portable ladders with scaffolds can be found in Subpart X, (Stairways & Ladders) 29 CFR 1926.1053(b). And finally, the regulations applying to clamp-on ladders can be found at 29 CFR 1926.451(e)(2). OSHA Letters of Interpretation can be found at the OSHA website,www.osha.gov.