#1 Fall Protection – Residential construction 6’ or more: 1926.501(b)(13)
#2 Fall Protection – Unprotected sides and edges: 1926.501(b)(1)
#3 Aerial Lifts – Fall protection: 1926.453(b)(2)(v)
#4 Head Protection: 1926.100(a)
#5 Fall Hazards training program: 1926.503(a)(1)
#6 Scaffolds – Fall protection: 1926.451(g)(1)
#7 Portable ladders 3’ above landing surface: 1926.1053(b)(1)
#8 Scaffolds – Access: 1926.451(e)(1)
#9 Scaffolds – Platform construction: 1926.451(b)(1)
#10 Training for employees using scaffolds: 1926.454(a)
What is the significance of this list? One factor is that some people just don’t get it. For example, how can fall protection be a problem on scaffolding? Fall protection has been required by federal OSHA since 1971 and it has been a consensus requirement for many years before that. I fact, I have an illustration from an industry magazine published in the 1920’s that warns workers that guardrails are to be used on scaffolds. It is difficult to imagine that a scaffold user doesn’t know that he/she is supposed to have fall protection at heights. Some people just don’t get it. Let’s face it: Scaffolding isn’t so complicated that the typical user cannot grasp the concept of utilizing fall protection. Rather it is the idea that “it won’t happen to me.” Or perhaps the user lacks the training (Violation #10) that results in a false sense of security. Do you know of anybody that has planned on going to work with the intent of falling off a scaffold?
#10 counters the efforts of the Scaffold Industry Association. The association’s training programs have been available for a sufficient number of years that scaffold training violations shouldn’t be in the top 100 much less the top ten. What gives? I don’t have the answer to this one. My experience suggests that employers and employees just don’t see the need for training. They apparently do not recognize the direct relationship between training and a safe work environment. This is very evident in this list of violations. In all cases, except for # 5 and # 10, the equipment is available to eliminate the described hazard. Obviously, it is the lack of training that really creates the hazards, not the lack of equipment or technology.
Check it out: Do ladders exist that can extend more than 3 feet above the landing surface? Of course. Do scaffold suppliers have various components to provide safe access? Of course. Can platforms be constructed so they are safe? Of course. Can scaffolds be constructed with guardrail systems? Of course. Is it possible to use an aerial lift while wearing personal fall restraint? Of course. So what is the problem? What must be done to get the industry off the top 10 list?
Again, I don’t have the answer but I can throw out a few thoughts that should be considered in developing a solution. One of the basic problems is in communication. As politically sensitive as the topic is, the language issue must be resolved. There is no way that education and training can be effective if the recipient cannot read and write. Signs, pictures and illustrations are nice but you can dumb down the situation only so far. At some point the employee must have the skills to perform his or her task, even at the most basic level. Directly related to this issue is the lack of a common language. For safety issues, it is not nationalistic honor or pride. It is safety, pure and simple. How can safety be achieved when the workers on the jobsite speak English, German, Polish and Spanish, as occurred on a jobsite that I was recently on?
As we all know, the level of safety varies from country to country. What happens when a worker, who is trained in a situation with sub-adequate conditions and rules, arrives in the United States to work at a jobsite that must comply with the federal OSHA standards? Is it reasonable to assume that the worker will pick up the skills by practice and observation? I think not. This is an accident waiting to happen or at least a violation waiting to happen. We owe the employee more than that and the employee owes himself more than that.
Personal and corporate responsibility must be considered/reconsidered. Employers and employees must share in the responsibility for safe work practices. It cannot be left to the employer any more than it can be left to the employee. It cannot be left to technology or equipment; it must involve human actions, opinions, thought processes and attitudes. It is time to make changes in the emphasis and it’s time to recognize the fundamental issues. Let’s face it, a ladder not extending 3 feet above the landing surface isn’t causing 100 scaffold fatalities a year—it’s a lack of respect for the fragility of the human being. Do you have ideas on how to fix it? If you do, I’d like to hear about it. Also, share your ideas at the upcoming SIA convention. It is time to fix the entire system. Understand?