Once again, scaffolding has shown its ability to frequently receive OSHA citations! In fact, it shows up in the number three spot on the famous “OSHA’s 2014 TOP TEN Most Frequently Cited Violations” list. (See Figure 1) According to OSHA, there were 4,543 scaffold violations: that’s about 17 every workday. Unfortunately, it is unclear as to the breakdown of the citations; which hazard does each citation specifically address. (Note that Fall Protection still holds the number one position with 7,170 citations, about 27 per workday. Again, it is unclear what type of fall hazard existed that warranted a citation.)
How about having some fun with statistics? While 17 scaffold violations per day is significant, it is worth comparing the 17 violations per day to the number of workplaces and workers in the construction industry. According to OSHA, there were 89,664 inspections in 2013, about 345 each work day across the United States and its territories. That works out to approximately six per state/territory each day. Depending on the population of the state where you do business, this may or may not have you concerned. Since there are 8 million worksites containing 130 million workers, the odds of having an inspection at least once in a year is one percent. Does that mean that for every scaffold the same odds exist? Yes and no.
Not every worksite has a scaffold so those sites should be excluded from the count. And since the 8 million worksites include construction, manufacturing, retail and a zillion other worksites, an adjustment needs to be made if only the construction sector is to be considered. So, as an example, let’s assume (guess might be a better word) that twenty percent of the work sites are construction related and that seventy five per cent of those construction sites have scaffolding. That means that there are 1.6 million construction projects and that 1.2 million have scaffolds. Obviously the scaffolds will vary in size based on the scope of each project. While on one site only a small rolling tower may exist, on another site a scaffold 150 feet tall may have been constructed. For argument’s sake, let’s argue that on average each site has a supported scaffold that is 7 tiers high and 100 feet long. (Of course any of these projects could have aerial work platforms and/or suspended scaffolds but these scaffolds will not be considered for this example.) Depending on the equipment being used, the scaffold could have more than 1,000 components. This would then mean that there could be 1,000 problems which in turn have the potential of creating 1,000 citations. Since we assumed that there are 1.2 million jobs with scaffolds, and each job has 1,000 scaffold components and potentially 1,000 violations, there are then 1,200,000,000 (that’s 1 billion, 200 million) possible violations looking for citations. This number suggests that since there were only 4,543 citations, either the compliance officers aren’t doing a very good job or only 0.0004 % (that’s four-ten thousandths) of scaffolds had problems. Since OSHA compliance officers do a good job, it can only be concluded the industry is doing a superb job of constructing and using scaffolding since 99.99962% are flawless!
Although one could reasonably assume that there may be a flaw or two in this analysis example, the fact still remains that the overwhelming majority of scaffolds are constructed properly. Therefore it is time to step back and consider whether the present method of measuring safety is accurate since it is well known that accurate measurement is critical if the root cause of scaffold accidents is to be determined. Furthermore, how can full safety be achieved if the problem isn’t understood?
Historically, scaffolds have been considered to be dangerous and downright life threatening. This perception assuredly contradicts the evidence: How can scaffolds be dangerous if 99.999% of scaffolds are constructed without flaws? Furthermore, how can scaffolds be dangerous if each scaffold is designed and constructed properly? A properly designed and constructed scaffold has no hazards. And please, don’t tell me that you can still fall off a properly constructed scaffold. A properly constructed scaffold won’t let you fall off—you’ll have to jump.
On the surface, the “OSHA Top Ten” continually paints a bleak picture for scaffold safety. But this analysis shows that it is just not true. Unfortunately the statistics are taken at face value without considering the bigger picture. While any violation is undesirable, it doesn’t necessarily indicate a serious flaw in the scaffold industry. And finally, the Top Ten list only indicates the number of citations written, not an accurate count of the citations that ultimately remained and accepted by the employer. Nor does the list indicate the severity of the violations. Frankly the only conclusion that can be made is this: Scaffolding shows up on the OSHA Top Ten list—so what. The list is meaningless in that it fails to truly indicate the safety or menace of scaffolding. On the contrary it misleads and thus wastes the efforts of those who are assigned the task of evaluating jobsite safety. It would be better to not have the list. Think about it.
OSHA TOP 10 MOST SERIOUS VIOLATIONS
1. Fall protection (c)
2. Hazard communication
3. Scaffolding (c)
4. Respiratory protection
5. Ladders (c)
6. Powered industrial trucks
8. Wiring methods
9. Machine guarding
10. Electrical: systems design
C = Construction standard