Here Are Some Scaffolding Answers!

By David H. Glabe, P.E. / March 7, 2016

Here are answers to frequently asked (and some not so frequently asked) questions regarding scaffolding and related subjects:

Q: Do scaffold users have to have scaffold training.

A: Of course they do—why wouldn’t they? They need to be trained in fall protection, access, falling object protection, proper use, the scaffold load capacity, electrical hazards and proper handling of materials on the scaffold. [OSHA 29 CFR 1926.454(a)]

Q: Does a ladder have to stick 3 feet above the scaffold platform?

A: Only if it is a portable ladder. Purpose built attachable scaffold ladders do not although it is a good idea unless you have hand holds (such as the scaffolding) available.

Q: Does a portable ladder have to be tied at the top?

A: Not if it is sticking 3 feet above the platform.

Q: A supported scaffold ladder is straight up and down like a fixed ladder and clamped to the scaffold. Doesn’t that make it a fixed ladder?

A: Nope. It’s an attachable ladder purpose built for scaffolds. OSHA 29 CFR 1926, Subpart X – Stairways and Ladders does not apply. (Read the Subpart X Scope and Application)

Q: Do I have to always use scaffold grade plank on my scaffold?

A: Not if your scaffold has to comply with the Construction Industry OSHA standards. If you have to comply with the General Industry or Maritime standards, then the plank must be scaffold grade. Of course the SAIA recommends that you always use scaffold grade plank or equivalent.

Q: What’s a high wind?

A: That’s subjective. If you get blown off the scaffold, that is a high wind. It is up to the Competent Person to determine what a high wind is. I would take jobsite conditions and the work activity into consideration when determining if it is time to vacate the scaffold. 20 – 25 mph is a popular maximum wind speed for supported scaffolds although I have been on scaffolds in 50 mph breezes. [You don’t get any work done because you’re spending all your time hanging on but you get bragging rights.] The SAIA Code of Safe Practices for Suspended Scaffolds recommends 20 mph for single point and 25 mph for two point suspended scaffolds.

Q: Is a “Self-Propelled Elevating Work Platform (aka scissors lift) an aerial lift or a Mobile Scaffold?

A: According to an OSHA Letter of Interpretation (LOI), OSHA thinks it’s a supported scaffold, similar to a frame scaffold. The industry knows it is an aerial platform because the consensus standards for it are in the ANSI A92 family of standards, not in the ANSI A10.8 standard which addresses the typical frame, systems, tube & coupler, and other like scaffolds.

Q: Are the OSHA scaffold standards instructions on how to use scaffolds?

A: Heck no; they are minimum requirements for safety, minimum expectations. In fact, you have to be trained in scaffolding before you can understand the regulations. Reading the standards does not a Competent/Qualified Person make!

Q: Why do I have to have a guardrail on a suspended scaffold if I am wearing personal fall arrest equipment?

A: We don’t want you to fall off the platform since catching you isn’t fun.

Q: Does that mean that when I am on a single or two point suspended scaffold I have to not only utilize a personal fall protection system but I have to be behind the guardrail system on the platform.

A: Duh—yeah.

Q: What about a multi-point suspended scaffold?

A: It depends on the scaffold. If the deck has many suspension points and the deck is very rigid, personal fall protection may not be necessary. On the other hand, if the deck is flexible, failure of one line can dump you off the platform. Ask the qualified designer what is required for fall protection. If nobody knows, use both a guardrail and personal fall protection. I would also recommend looking for a new job if nobody knows what the fall protection requirements are!

Q: If I stand on a plastic five gallon bucket, is it a scaffold?

A: You bet it is. A scaffold is any temporary elevated platform and its supporting structure used to support workers or materials or both. Assuming you turned the bucket over before you stood on it, the bottom of the bucket is your platform and the sides of the bucket are the supporting structure. I cannot tell you what the handle is.

Q: Does that mean that if I stand on a table I have to comply with the OSHA scaffold standards?

A: Why not? You’re using the table as a scaffold.

Q: Do I have to comply with the OSHA standards or do they only apply to my employer?

A: Nice try. The OSH Act of 1970 explicitly states that both the employer and the employee have to comply with the standards. [This is known as the “General Duty Clause” of the act.]

Q: What else does the General Duty Clause say?

A: It requires that the employer “shall furnish to each of his/her employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his/her employees.” This is also known as “Section 5(a)(1).”

Q: Do the OSHA standards cover all workplaces?

A: No. The federal OSHA standards do not cover state and local government employees; they apply only to the private sector.

Q: Do all 50 of the United States enforce the federal OSHA standards?

A: No. 21 states and 1 US territory have state plans that cover both private and state and local government workplaces. 5 states and 1 US territory cover state and local government workers only. Most states use the federal standards. Certain states have added to or revised the federal standards for use in their states. California’s OSHA scaffold standards are completely different from the federal standards.

Q: Why do states change the federal standards?

A: I have no idea—a broken arm in the Virgin Islands is the same as a broken arm in Alaska.

Q: I am on a project where the Army Corps of Engineers had authority. Do they use the federal standards?

A: Yes and no. They have to comply with federal OSHA but they also have standards that are referred to as EM-385 that are part of the contract. And yes, the EM 385 scaffold standards are much more stringent and more confusing.

Q: I was told that 19” is the maximum first step for accessing a scaffold. Is that correct?

A: Nope. It is 24 inches. 19 inches is the maximum first step for everything except scaffolds.

Q: Where do you find all this information?

A: I make it up, just like a lot of people on the jobsite. JUST KIDDING! The OSHA standards can be found at www.oshsa.gov; the Codes of Safe Practices can be found at www.saiaonline.org and www.ssfi.org. DH Glabe & Associate also keeps a wide variety of info on its’ resources page www.dhglabe.com/free-resources. The ANSI A92 standards can be purchased from the SAIA. Other standards can be purchased from ANSI or the American Society of Safety Engineers. Training on how to use scaffolds can be obtained from the SAIA and other sources. Be sure to investigate the quality of the training before purchasing—there are a lot of supposed experts who do not have the credentials.

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David H. Glabe, P.E.

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