Have you ever been asked if a scaffold is OSHA approved? Or perhaps you have been asked if the scaffold is an “OSHA scaffold.” When the question is asked, it has been my experience that the person really is asking if the scaffold in question complies with the applicable OSHA standards. This begs the question: What are the applicable standards?
If a scaffold is constructed of typical scaffold components, used for the support of a temporary elevated platform that supports workers and/or materials, the answer is straightforward. But what happens if non-typical components are used, or if the structure isn’t a scaffold after all? How do you determine what the applicable standards are? How do you convince others of your evaluation. While there are no standard procedures, here are the questions I ask to ascertain the correct application of standards, particularly when scaffold components are used in nontraditional ways.
So, how does this really work? Let’s try an example or two. First, suppose we have three planks supported by two oil barrels. There is a stepladder next to one of the barrels so the worker can access the platform. What is this structure? No scaffold frames, tube & clamp, or other standard scaffold products are involved. Is this a scaffold? Yes it is. How do I know this? The OSHA definition for a scaffold is that a scaffold is any temporary elevated platform, and its supporting structure, used to support workers or materials or both. In this case the barrels support plank that support workers. (Please don’t get excited and think I endorse this type of “scaffold.” I use it for illustrative purposes only.) In this example, the scaffold standards apply.
For example two, suppose you observe a trash chute that is thirty feet tall. The chute is constructed of plywood supported by a rectangular structural tower constructed from frame scaffold components. The plywood walls are inside the tower, forming a rectangular chute that is 5 feet wide, 7 feet long, and 30 feet high. What is this structure? Is it a scaffold? Do the scaffold standards apply? I think the scaffold standards do not apply. While the chute is supported by a structure consisting of standard scaffold components, it is not being used to support an elevated temporary platform for workers or materials. Therefore, by definition it is not a scaffold and Subpart L of the OSHA standards does not apply. What standards do apply? The demolition standards, Subpart XXXXXXXXXX probably apply. General safety and health standards apply. The OSHA General Duty Clause, which requires employers to provide a hazard free workplace, probably applies. During the erection of the support tower (note that I did not say scaffold tower) the OSHA fall protection standards, Subpart M, apply. Please remember that while the scaffold standards do not apply, it would be prudent to follow the manufacturer’s recommendations for the construction of the tower.
Scaffold systems are marvelous tools since they can be used in many innovative ways.