Applying the correct regulations and working safely while constructing shoring & formwork
When it comes to providing fall protection and access for shoring and formwork erectors, OSHA scaffold standards apply to scaffolding and nothing else; so what does a shoring or formwork erector do? The most efficient answer is to not fall while erecting the equipment.
Shoring Tower or Elevated Work Platform?
In order to apply the correct regulations, the first step in providing fall protection and access for shoring and formwork erectors is to determine if they are actually erecting shoring towers or an elevated work platform so they can reach the work area.
While both scaffold construction and shoring construction involve the assembly of towers, the use of those towers is completely dissimilar. Shoring towers are used to support a deck that is used to support concrete. Scaffold towers are used to support an elevated platform that is used to support workers or materials or both. But aren’t shoring decks supporting workers who are installing the rebar and inbeds? Yes, but those workers are doing work to the deck, not workingfrom the deck. And that’s the big difference.
Once it has been determined that the towers being constructed are shoring towers, and the deck on top is the formwork for the concrete, then appropriate fall protection and access standards can be applied.
The fall protection standards are found in Subpart M of the OSHA construction standards, 29 CFR 1926. The access standards are found in Subpart X of the same standards.
Access or Work Surface?
Are the erectors climbing frames to construct a tower using the frames to gain access, or working on an “unprotected side or edge of a work surface?”
Per OSHA, when the erectors are climbing and assembling the frames, it is a “vertical work surface.” So if an erector is climbing/assembling a shoring frame, it is not access—it is a work surface and fall protection is required to be compliance. It’s reasonable to conclude that both a guardrail system and safety net system aren’t applicable, so that leaves the personal fall protection system to get the job done.
Fall protection is required once a worker is six feet above the level below. The anchor to which the lanyard is attached must hold 5,000 lbs. unless it is designed by a Qualified Person and has a safety factor of two. This can be extremely problematic at low heights above the surface below since it is very rare to have an anchor point above the worker. (Shoring is normally used to construct the top floor of a building with the erectors constantly above the top floor. While dismantling, it is equally difficult, near impossible to provide fall protection at the same low heights since lateral movement and limited fall distance are mutually exclusive—you normally can have one or the other but not both.)
When it comes to providing fall protection for the erectors constructing the deck— installing the joists, stringers, and plywood— there is some allowance for “leading edge” erectors. A leading edge is the edge of the formwork that is constantly changing due to the addition of additional decking. It’s considered to be an unprotected side and edge during periods when it is not actively and continuously under construction. Leading edge erectors are to be protected unless the employer can demonstrate that it is infeasible or creates a greater hazard to use fall protection. It is the employer’s obligation to prove infeasibility, not OSHA’s obligation to prove feasibility.
In a Nutshell
Fall protection is required when a worker is more than six feet above the level below whether on frames, vertical wall forms (except the scaffold platform attached to the wall forms where the scaffold standards do apply), or horizontal formwork—easy in principle, difficult, near impossible to execute. A company’s Competent Person is the one responsible to evaluate the situation and determine the applicable regulation.
While fall protection will keep you from falling off an elevated surface, proper access is necessary while getting to that work surface. Access is straightforward; if you are using a portable ladder, you must comply with the manufacturer’s recommendations and the regulations found at 29 CFR 1926.1050 through 1060. Make sure you have a ladder that has the correct capacity, is in good repair, and is installed correctly. This of course would include the correct angle of installation and ladder extension above the deck.
An employer has to have to have its Competent Person evaluate each situation, and when the situation changes – which may be daily—re-evaluate to determine the feasibility of providing fall protection in compliance with the applicable OSHA standards. It is expected that this can be done no matter the circumstances unless proven otherwise; and proving a negative is almost impossible.