Applicable Standards

By David H. Glabe, P.E. / June 1, 2008

Imagine this:  I am a scaffold erector and I enjoy my job.  I like erecting scaffolds.  I know how to build scaffolds but I don’t know much about all the rules that I am suppose to follow.  All I know is that all the platforms are suppose to have guardrails and I have heard that scaffolds are suppose to have toeboards—not sure when I’m suppose to install toeboards—just told that I should install them.  Why do I need a toeboard on an Army Corps job inOhiobut not an office building in Ohio?

Why are there so many different rules?   Don’t bother me with the regulations; just tell me what to do.  Why should it make any difference where I’m at or what project I’m on?  For example, take fall protection.  Isn’t falling inCaliforniathe same as falling inMassachusetts?  Please tell why I should have guardrails on a scaffold more than 7-1/2 feet above the level below inCaliforniabut at 10 feet inMassachusetts?  Better yet, why 7-1/2’ feet inCaliforniabut 10 feet on a casino inCalifornia?  And yet, if you are in a shipyard inCalifornia, working on a federal facility (Navy shipyard) you may have to comply with the Maritime Standards, 29 CFR 1915, which requires that fall protection is required on platforms more than 5 feet above the level below.  And then of course, you may be on a jobsite where the general contractor requires fall protection on all platforms more than 6 feet above the level below.

This isn’t easy for the typical scaffold erector.  I suggest that it is legitimate to ask why there should be so many heights for fall protection.  Why can’t the federal government get their act together and establish a common set of standards?  Why do the various agencies of the government insist on maintaining separate standards for the same things?  Is it possible that maritime scaffolds are that much different that construction scaffolds?  How about Army Corp scaffolds?  What would make this agency sufficiently different so the OSHA Construction Standards wouldn’t apply?  Unfortunately, I hope you aren’t looking for an answer here—I don’t have one.

It is my opinion that there are numerous factors involved in maintaining the status quo.  Unfortunately there isn’t much of a desire to make scaffold erection any easier for erectors, not to mention making it any easier for those charged with the task of enforcing the standards.  Is it realistic to expect a scaffolder to know all these standards and when they apply?  Even if you are the Competent Person, you have to admit that keeping track of all the variations of the same standard can be overwhelming.  Besides, I find it hard to believe that construction workers inMassachusettscan safely fall from higher distances than shipyard workers inMassachusetts.  The hazard is the same; why should the solution be different?  Unfortunately the remedy appears to be non-existent.  Well, maybe nobody really cares whether the standards are simplified or at least combined where it makes sense.  Perhaps it isn’t necessary because erectors don’t voice their opinions.  Maybe it’s not important because erectors and users aren’t complying with the standards no matter what they are.

As I said earlier, I don’t have an answer for coordinating the conflicting standards.  I also don’t know if there is a desire in the industry to do this.  I do know that it is illogical to maintain dissimilar standards addressing the same hazard.  What do you think?

Tags: Scaffolding Army Corps of Engineers OSHA Construction Standards OSHA Standards & Regulations Resources

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David H. Glabe, P.E.

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