While everybody says they are for safety, sometimes actions speak louder than words. As the saying goes, sometimes you can’t see the forest for the trees. The intrigue surrounding the scaffold regulations, as written by Federal Occupational Safety and Health Administration (OSHA) is surprising. If the questions and comments that I get are any indication, the struggle between regulatory intent and the letter of the law is only beginning.
As you already know, the new regulations have been written as performance standards as opposed to the old regulations which were written as specification standards. Performance standards, in my opinion, are much better because they allow the scaffold erector and user greater flexibility in constructing a safe scaffold and complying with the regulations. With this flexibility comes a responsibility and, yes, an obligation for the erector and user to construct and use a scaffold in accordance with the regulations and safe industry practice. The performance standard also puts a greater emphasis on the intent of the scaffold regulations and, more importantly, a greater duty by the erector, user, and safety officer to understand the purpose of the regulations and the hazards that the regulations are addressing.
For example, what is the purpose of keeping the edge of a supported scaffold platform within 14 inches of the work surface? It should be obvious that the platform should be close to the work surface so that the worker cannot fall through the opening, yet still be able to work comfortably. The intent, therefore, is to provide maximum protection while still providing a useable scaffold platform. Suppose the space is 14-1/2 inches? Is this scaffold unsafe? Is there a hazard that wouldn’t exist if the space were 14 inches? I doubt it and yet one scaffold company actually was cited for this violation of the letter of the law. The intent of the regulation was lost somewhere in the process; safety wasn’t enhanced nor addressed. As an alternative look at this same regulation, suppose a scaffold platform that was 14 inches from the wall was occupied by a class of preschoolers. (I can’t imagine why the preschoolers would be on a scaffold but I can’t think of a better example!) In this case, the 14 inch space would be too large. Would the scaffold erector be cited or because the scaffold was within the letter of the law, would it be acceptable?
I emphasize the intent of the regulation. After all, the reason the regulation is there is to provide a guideline for safe activity. Numbers are only a handy excuse for NOT learning the purpose of the regulation. Can a stairway with a 25 inch first step instead of a 24 inch first step be that much more hazardous. I think not.
Finally, there appears to be a fixation with the training requirement that users and erectors know the capacity of a scaffold leg solely for the sake of having a number in case somebody asks, such as a safety officer. What seems to be missed by both the user and the safety officer is the intent of this requirement; that is, we don’t want anyone to overload the scaffold and collapse it. We also don’t want an erector to construct a scaffold that isn’t strong enough. That is why you should know the capacity of the scaffold. Not because OSHA says so, but because YOU should be concerned about your scaffold falling down and killing somebody.
Remember, when looking at the forest of regulations, don’t miss the beauty of the individual regulation. It is there for a reason; you need to recognize it if you are to use the regulations the way they are intended to be used.
P.S. If you aren’t concerned with the intent, only the letter of the regulations, frame scaffolds leg can support somewhere between 1500 and 3500 pounds per leg, depending on the manufacturer and the style of frame, tube and coupler scaffold can support about 3000 pounds per leg if it is constructed properly, and system scaffolds can support between 4000 and 6000 pounds depending on the scaffold configuration, the manufacturer and the bracing. Want more information? Contact your manufacturer, supplier, or a qualified person.