An explanation of the intent of the OSHA scaffold inspection standard
According to certain authoritative sources, scaffolds shall be inspected for defects. You ask yourself, why should it be necessary to inspect a scaffold? After all, if the scaffold erector is any good, shouldn’t the scaffold be perfect in all aspects and therefore be safe to use? Right, and nobody gets injured or killed while using a scaffold!
The federal Occupational Safety and Health Administration, OSHA, (one of those authoritative sources,) clearly specifies in Construction Standard 29 CFR 1926.451(f)(3), that “Scaffolds and scaffold components shall be inspected for visible defects by a competent person before each work shift, and after any occurrence which could affect a scaffold’s structural integrity.” This is an interesting statement in that there are several key requirements worth further clarification, particularly since readers of the standards tend to interpret this particular standard in a multitude of ways.
Before trying to interpret anything though, assuming that interpretation is even necessary, let’s look at the individual specified in this standard, the “competent person.” In brief, OSHA identifies a competent person as an individual who can identify a hazard, and has the authority to do something about it. The longer version expands that definition and requires the competent person to be familiar with the scaffold standards and with typical scaffold hazards. Does this not suggest that the competent person be familiar with the scaffold standards? Of course it does. Unfortunately, too many of us compare industry longevity with knowledge. In other words, since I’ve been involved with scaffolds for thirty years, I know everything about scaffolds. The flip side to this is the assumption that since I read (and somewhat understand) the scaffold standards, then I know everything about scaffolding. Fortunately, being a competent person is more than reading the standards or working with scaffolds for thirty years. In other words, you have to work at being a competent person. You truly must understand the hazards; in fact, you must be able to identify those hazards because others are expecting and relying on you, the competent person, to evaluate the scaffold and verify that it is safe.
Having clarified the issue of a competent person, the one issue in this standard that raises so many questions is the requirement that scaffolds be inspected “before each work shift and after any occurrence which could affect a scaffold’s structural integrity.” What is a work shift? What is an occurrence? Is it only in the morning? What happens at the refinery where there are multiple work shifts and multiple scaffolds? How often does an occurrence occur? We sure can play games with this one, can’t we? To determine what the standard is all about, we must look at theintent of the standard by asking the question: What hazard is OSHA addressing in this standard? What can happen if the scaffold in question is not in compliance? The answer is straightforward: Don’t use unsafe scaffolds. But how do we determine if the scaffold is safe? Hey, that’s where the competent person comes in! Before anybody gets on the scaffold, as in at the start of the work shift, the competent person should ask if the scaffold is in compliance with the standards. Are there any hazards with this scaffold that will expose the user to injury or death? Let’s face it. Who cares if it’s the beginning, the middle, or end of the work shift. Let’s not kill the user.
The bottom line on this standard is the simple fact that we want scaffold users to use only safe scaffolds. To achieve this goal, OSHA, and other agencies, such as the American National Standards Institute (ANSI), have required that scaffolds are to be inspected at sufficiently frequent intervals, by competent people, to ensure that the scaffold is safe. Furthermore, OSHA also requires that users, that’s right, users, are sufficiently trained to recognize scaffold safety hazards. Frankly, users are expected to know enough about scaffold hazards before they get on the scaffold so they stay out of harm’s way. There is no magic here. Unfortunately, it’s common sense that seems to get lost in the regulation. Make sure the scaffold is safe. If this means inspecting a scaffold three times a day, so be it. If it means inspecting it every hour, so be it. And when you inspect it, you must know what you’re looking for, using your ability to identify the hazard, and your authority to do something about it.