While the construction and engineering industry does come with a certain amount of inherent risk, contractors can be proactive about safety on projects. OSHA sets strict guidelines regarding fall protection measures because falls are commonly responsible for serious workplace-related injuries and deaths. The National Safety Council finds that falls from height are the reason for the most non-fatal days of missed work. Keeping this in mind, contractors and engineers should ensure that all employees receive regular preventative training. Additionally, when working from any height, workers should be provided with the appropriate fall protection system.
In the construction industry, falls are the leading cause of workplace fatalities according to OSHA. In 2015 alone, 350 workers lost their lives due to completely preventable accidents. The National Safety Council found falls are responsible for the most non-fatal missed days of work. Clearly, falls and related accidents can be a large liability for any commercial project. However, with proper fall prevention techniques, contractors can protect their employees and profit margins all at once.
Earlier this year, OSHA made headlines for the way it would revise the regulations regarding fall protection for general industry.
Did you know about the change?
As explained in the regulations by the department itself, the modification accounts for modernization of technology along with updates to old regulations.
Facade design is an important aspect of any building project, but that doesn’t mean simply considering what the exterior of the finished building will look like.
Facade access design is an essential consideration. A good system will allow for maintenance to take place safely and at a reasonable cost. Maintenance operations can include setting up advertising, cleaning windows, fixing damage and more.
Here are five essential things you need to know about facade access design.
It has been said that the best solution for fall protection is to not fall, but as falls account for several deaths on construction sites, it turns out this plan doesn’t work out and will make OSHA very grumpy. This topic may be stale news to the salty veterans who have been around the block a time or two but I would be willing to bet that there are very few who consider all aspects of a fall protection every time they don their harness.
An inside look at why fall protection anchors must be tested
Fall protection! When you put on your harness, tie off to a fall protection system, and step to the edge of the roof on a 20 foot tall building, do you know that you are truly safe? Or is this maybe just a false sense of security that you have been lulled into? Would you feel different if this were a 200 foot tall building?
As we all know, the components of a complete fall protection system are the user’s personal fall protection equipment and a suitable anchor or lifeline to connect it to. If the system is properly designed, constructed and used, it will ensure that you will walk off the jobsite at the end of the day safe and sound. As a user, you can only control the “use” aspect of the system so a great deal of responsibility is on you to ensure your own safety. If you are a gambler, you can take your safety on faith. However, those who do not want to rely on dumb luck need to know their fall protection system.
First, the simple stuff: your body harness and lanyard. They should be purchased from a reputable source with readily available design and testing data from the manufacturer. Utilizing your Fall Protection User Training, you should be able to perform a visual inspection of the equipment to check for damage or excessive wear. If all looks good, you should feel comfortable that your personal fall protection equipment will do its job.
On the other hand we have the anchor portion of the system – this is not so easy. You can look for visible signs of damage or corrosion, but the truth of the matter is that in most cases you have no idea what is behind or underneath the anchor itself. It is in these areas where corrosion hides and maintenance tends to neglect. The truth of the matter is that if the anchor was not designed and installed properly, no amount of maintenance can make it safe to use! You may be thinking the anchor is fine and dandy because that steel beam over there is “big”, or that wall looks “solid” . . . there is no way that it won’t hold 5,000 pounds! This may be true, but as you stand there looking at the “big” steel beam ask yourself this: what is holding the beam in place? Okay there is a steel column at both ends, but what are they attached to? If you don’t know, how can you really be sure that “big” steel beam isn’t going to follow you over the edge of the roof if you fall?
OSHA requires that all permanent fall protection anchors must be tested upon installation and be visually observed annually if they are to remain active. The fact of the matter is that many property owners simply do not know about these requirements as many building anchors are used daily which have never been tested or inspected. This puts you at risk of injury, and the property owner and your employer at risk of a hefty lawsuit if something were to go wrong.
We were recently involved in a project which involved the load testing of existing fall protection anchors around the perimeter of the mechanical penthouse. The anchors were installed on the outside face of the brick veneer and consisted of a steel eye welded to the center of an 18”x6”x 1/8” thick steel plate. The plate was bolted to the wall with two ½” diameter threaded rods and nuts at both ends. On this particular structure, we could observe that the other end of the connection inside of the penthouse was identical to the connection on the outside.
From the pictures above, you may be thinking it looks like someone clearly put some thought and effort into installing these anchors so they must have been designed and installed properly. No rust is apparent and the wall appears “solid” . . . why do they need to be tested??? The reason we were asked to test the anchors is because someone didn’t feel like gambling as they prepared to hang off the side of the building and asked the correct question “can I get a copy of the latest testing and inspection reports?” As it turns out there was no record that the anchors had ever been tested or inspected, and more disturbing that they may have never been designed either. Fortunately in this case, the property owner and contractor were well aware of the OSHA requirements and requested the anchors be tested before use.
Armed only with a single architectural section of the penthouse wall, we felt it would be prudent to perform a structural investigation prior to performing any testing. During this investigation we discovered that the two threaded rods were installed adjacent to the light gauge steel studs at most locations. Running a computer modeled analysis of this configuration yielded results which confirmed that not only were the anchors not suitable for their intended use, but that testing them could potentially damage the building!
Since the existing anchors were determined to be inadequate, new anchors were designed and installed and the old anchors removed and/or taken out of service. During the testing of the new anchors, we were asked to test one of the existing anchors in a location that a new anchor could not be installed due to equipment conflicts inside the building. The test was halted at only 1400 pounds as the outside plate had already deflected ½ inch with this minimal load applied to it!
The topic of fall protection anchors is cussed and discussed all the time, but we still have individuals who are either uninformed regarding the OSHA standards or they simply don’t care. The anchor may look “big”, and that wall may appear “solid”, but the only way to know with certainty that it is safe is through proper testing and annual observation. As a user, you need to be cognizant of your own safety and simply ask for the latest fall protection anchor testing or inspection report before you go trusting your life to it. This will provide you with peace of mind, and you may educate someone else about the OSHA standards in the process which may save another life down the road.
An assessment of the OSHA standards that apply to fall protection for scaffolds and scaffold users and erectors.
Have you ever asked yourself how many ways fall protection can be screwed up, particularly on scaffolds? Well, based on my experience, misapplication and misuse is only limited by the number of workers on the job. Rationale doesn’t seem to be a consideration nor does common sense. I recently testified as an expert in a lawsuit where the employer insisted that the reason the employer did not want the employees utilizing personal fall arrest equipment is because if the suspended scaffold fell it would entangle the employees in the rigging. Lucky for the employer the employees listened. Unlucky for the employees, they rode the scaffold down and died in the process.
So why is it so difficult to provide fall protection? Is there magic? Nope-no magic; you just have to know and understand how this stuff works. Let’s review a few things and see if we can sort it out.
Fall protection regulations/standards can be found in a number of references. In construction, the federal OSHA standards address scaffold fall protection in Subpart L and M. Well, actually it is addressed in Subpart L, not M. However, if you are going to use personal fall arrest equipment, then you have to use the applicable standards that are found in Subpart M, namely 29 CFR 1926.502(d). This is where all the good regulations regarding lanyards, connectors, dee-rings, snaphooks, horizontal lifelines, anchor strength, freefall distance, deceleration distance, maximum arresting force and related topics are hiding. In fact part of the feasibility test for scaffold erector fall protection is located in 29 CFR 1926.502(d). Of course, this is where plenty of the confusion starts since it appears the 502(d) standards are either misunderstood, misread, or maybe just not read. Here are a few of the myths and misconceptions that occur regarding the use of personal fall arrest systems (PFAS):
- Using (not wearing but actually using) PFAS won’t hurt you;
- Many people actually use PFAS;
- Tying off is the same as fall arrest;
- 100% tie-off works;
- Scaffold erectors are exempt from fall protection;
- Scaffold erectors aren’t exempt from fall protection;
- Restraint is the same as fall arrest;
- Positioning is the same as fall arrest;
- PFAS anchors must hold 5,000 pounds;
- Guessing an anchor can hold 5,000 pounds is acceptable;
- Nobody knows how much force is exerted on the anchor when an employee falls;
- The potential loads on horizontal lifeline anchors aren’t very high;
- The 5,000 pound anchor strength is based on science;
- You don’t have to be a competent person to determine if another is competent;
- The Goodyear blimp doesn’t make a good anchor;
- Money (financial burden) cannot be included in feasibility;
- There is an OSHA definition for “feasibility”;
- An anchor that looks good works;
- A scaffold erector can tie off at her feet, especially if it looks good;
- Supported scaffolds make good anchors;
- Supported scaffolds don’t make good anchors;
- You can tie off to scaffolds;
- You cannot tie off to scaffolds;
- All OSHA compliance officers can correctly evaluate PFAS;
- All scaffold erectors can correctly evaluate PFAS;
- All employers can correctly evaluate PFAS;
- 100% tie-off is the same as 100% fall protection.
If you think any of these myths are true, you aren’t the competent person you think you are. Well, except for the Goodyear blimp thing; that may be true! The point here is that too many people have the apparent authority to promulgate inaccuracies. Personal fall arrest is quite simple in theory, difficult in practice. The freefall distance is a critical component that directly impacts the required strength of the anchor. Likewise, the deceleration distance has a direct impact on the anchor load. More freefall and less deceleration distance dramatically increases the anchor load. (Think jumping into a pool full of marshmallows as opposed to landing on a concrete sidewalk.) Is insisting that the leading edge scaffold erector tie off at his feet really any better than allowing him to use his skill and experience to minimize the fall hazard through the use of safe erection techniques?
Finally, the fall protection standards work for stationary employees; that is an employee working in one location, rather than walking back and forth over a distance as scaffold erectors tend to do. A vertical lifeline is not conducive to straying horizontally from the anchor and horizontal lifelines only work if there is no scaffold above you. Besides, the anchor in a horizontal line can easily see load in excess of 10,000 pounds if not rigged properly; it’s tough to get a scaffold to hold that.
What is a person to do? Well, for supported scaffold erectors complying with 29 CFR 1926.451(g)(2) would be a good place to start. This standard requires that the employer have a competent person “determine the feasibility and safety of providing fall protection for employees erecting or dismantling supported scaffolds.” Of course, this standard doesn’t say that you have the right to tell the competent person that he/she is wrong. This standard doesn’t say you get to question the decision. But if you are competent, this standard sure gives you the right to determine if he or she is indeed competent! In other words, be sure you’re sure before you see if they’re sure. Think about it.
An argument for re-establishing the Shoring & Forming Council in the Scaffold and Access Industry Association.
I recall my first involvement with the Scaffold Industry Association, SIA, in the early 1980’s. I was impressed by the people who were genuinely involved in making the use of the scaffolding and related products safer. I also recall how I was railroaded into taking the minutes for council meetings! In fact, I was inducted (or abducted) into the role of scribe for the Shoring and Forming Council. You read that correctly. Back then there was a Shoring and Forming Council. There also was no Fall Protection Council, Aerial Lift Council, or Hoist Council. Over the years the focus of the association has changed, evolving into an organization that emphasizes the various forms of access for workers. Concurrently, shoring and forming slowly diminished in scope and involvement to the point that it is no longer represented in the SIA.
This doesn’t mean that there are no members who are involved with shoring and forming. It also doesn’t mean that there are no issues with the use of these products. In fact, there actually is more commonality between scaffolding and shoring than you might think. On the other hand, scaffolding is definitely not shoring and shoring is not scaffolding. For this discussion, we’ll leave wall formwork alone except for the fact that the work platform on a wall form is a scaffold and consequently the scaffold standards in federal OSHA 1926, Subpart L apply.
What are the common elements between shoring and scaffolding you may ask? Well, fall protection is a common element; access is a common element; falling object protection is a common element; and, capacity and strength are common elements. The significant difference between scaffolding and shoring is that a scaffold is a temporary elevated platform and its supporting structure used to support workers or materials or both. Shoring, on the other hand, can be a system of structural elements used to support the formwork for concrete (the Jell-O® mold that holds the liquid concrete). Shoring can also be a system of structural elements used to support existing structures such as buildings while repairs or modifications are being performed. Since shoring and scaffolding are different structures, different OSHA standards typically apply although there is overlap in a number of areas. That is where the similarities come into play and thus it makes sense that the SIA should consider resurrecting the Shoring and Forming council.
For example, fall protection for shoring erectors has the same issues as fall protection for scaffold erectors. For new concrete construction, the shoring equipment is always at the top of building (that is logical) and consequently, there is no convenient anchor above the erectors unless the Goodyear® blimp is in the neighborhood. Supported scaffolding can have the same issue. Interestingly enough, a review of the OSHA standards show that the Construction Industry fall protection standards are applied by OSHA through the use of Letters of Interpretation. Unfortunately, it is a circuitous route that attempts to apply the standards in creative ways so as to justify a desired outcome. The results are confusing requirements for shoring erectors to contend with during their work.
Access for both scaffold erectors and shoring erectors is an intriguing topic for those who attempt to apply inappropriate standards. OSHA considers shoring frames to be working surfaces and therefore fall protection and/or positioning devices are required. If these same frames are used as scaffolding, and they can be, then they can be climbed by the erectors. Confused yet? Wait—there’s more! Access for shoring can really be interesting. While the erector shouldn’t climb the frame because it is not a ladder but rather a working surface, the erector doesn’t need to comply with the ladder standards because his access continues to move while the shoring is constructed and the access requirements of 29 CFR 1926-Subpart X were never intended to apply to this work activity. Are you confused yet?
The final frustration is when the compliance officer or site safety employee can’t figure out whether you are working on scaffolding or shoring. Applying the scaffold standards to the erection of shoring is like trying to apply the fixed ladder standards to a scaffold attachable ladder—it doesn’t work.
The Scaffold Industry Association members have a wealth of experience and expertise that can be used to clarify the intent and application of the standards while making life easier and safer for both the erectors and users of temporary structures. Is it time to resurrect the Shoring and Forming Council? I think it is.
Scaffolds used in locations such as refineries, chemical plants and power stations are often referred to as industrial scaffolds, suggesting they are unique to that environment. But are they? Is there something mysterious going on in the refinery that transposes a common scaffold into a magical load bearing wonder that supports workers at heights? Or is that scaffold just a regular common scaffold similar to a commercial or residential scaffold?
I believe the answer is somewhere in between. Well, that stuff about a scaffold being transposed is a bit of a reach (no pun intended) but one significant difference between industrial and other scaffolds is that the industrial environment produces scaffold work habits not often seen in the commercial sector. One conspicuous example is scaffold inspection. US Federal OSHA requires that scaffolds used in construction be inspected before each workshift by a competent person [29 CFR 1926.451(f)(3)]. In the industrial environment this requirement is taken seriously. Frequently the inspection task will be assigned to one company although multiple employers may be using the scaffold during that workshift. More often than not, the scaffold company that erected the scaffold will have that duty. Of course, this doesn’t mean the scaffold users don’t have to know anything about scaffolds nor does it relieve them of the obligation to use a safe scaffold. After all, the OSHA standards involve all of us [29 CFR 1926.454]. Once the scaffold is inspected at the beginning of the workshift (notice that it isn’t each day; it’s before each workshift) [29 CFR 1926.451(f)(3)] a record may be made of the inspection. This record may be a simple tag or it may be as complex as a written record that is retained for the duration of the project. In conjunction with this method of inspection is the absolute rule that no one modifies, changes, dismantles or messes with the scaffold other than the workers assigned the task of scaffold assembly [29 CFR 1926.451(f)(7)]. Frankly, this is why the sole source inspection and tagging system works in the industrial environment; nobody messes with the scaffold.
Unfortunately, the same cannot be said about the commercial or residential environment. In fact, most workers on commercial job sites, based on my experience, consider themselves experts in the design and erection of scaffolding and therefore can do whatever they want with the scaffold. Even when the general contractor attempts to implement the controls seen in a refinery, the controls are typically circumvented by those who have the least knowledge and are consequently most exposed to injuries and death due to unauthorized modification of the scaffold.
Another example of the unique environment found in industrial scaffolds can be seen in the complexity of the constructed scaffolds. Because of piping, structural elements, electrical lines and other obstructions it takes considerable skill to erect a scaffold in a refinery or power plant. (Now, before you professional commercial scaffold erectors get mad at me, I’m not suggesting that professional commercial scaffold erectors are not qualified.) Those charged with industrial scaffold erections typically comply with the OSHA standard that specifies that scaffolds shall be erected by “trained and experienced” workers [29 CFR 1926.451(f)(7)]. Such may not be the case in commercial construction where the painter, who knows how to paint, may know very little about scaffolding but erects the scaffold anyway. In that case, the scaffold is erected for the convenience of the painter and may not work for the glazer. Industrial scaffolds, on the other hand, are often erected for all the trades to use or, if that is not possible, the scaffold is dismantled and re-erected.
Environmental controls appear to be more restrictive in industrial applications as well they should be. However, lessons from the power plant could be learned in the commercial project where we still fight resistance to eye protection, hearing protection and other equipment meant to protect the worker. As for the residential market, some days it seems hopeless to expect anything.
Fall protection is another aspect of the industrial market that is not as readily appreciated in the commercial or residential market. It is not uncommon at a chemical plant to not only expect workers to work on fully guardrailed platforms but to utilize personal fall protection equipment and tie off when they get to their work station. While this is a trend among large general contractors in the commercial construction market, the practice is considerably behind the industrial market in implementation. And again, when it comes to the residential market, personal fall arrest equipment usage is rarely observed. (Of course, I’m not endorsing the concept of both guardrailsand personal fall arrest equipment since it is really rather redundant; I’m just describing my observations.)
How about scaffold platforms? This is interesting since industrial scaffold platforms typically have more obstructions and penetrations than a commercial scaffold will ever see. While steel plank are more common in industrial scaffolds and plywood is commonly used to cover gaps since the gaps are less tolerated than in commercial installations, it is not uncommon to notch wood plank so it will fit around an obtrusive pipe or conduit. Commercial scaffolds usually have a clear platform that is easier to erect and use.
Finally, access in the industrial environment is usually more difficult than in the commercial scaffold application. Attachable/clamp-on ladders are the access of choice for small platforms and limited use in the refinery or power plant since they are easier to install around obstructions. Of course, where access for a large number of workers is needed, a systems scaffold stairway is commonly used. Commercial scaffolds will utilize stairs and ladders but also will utilize frame scaffolds and the access these frames provide. In residential applications access is anybody’s guess and a ladder sighting at a house is a pleasant surprise.
The bottom line however, is that the industrial scaffold serves the same purpose as a commercial or residential scaffold in that it provides a safe temporary elevated platform to support workers or materials or both. Where the scaffold is erected and used matters not—it still has to be erected and used correctly.
Fall protection is a huge topic these days what with people falling down and falling from heights. And since scaffolds are, by definition “any temporary elevated platform,” the issue of fall protection is significant, especially since most scaffold fatalities are due to falls from heights. It doesn’t have to be this way. Scaffold suppliers have this really cool product called a guardrail that when used properly, will keep you from falling. And if you don’t like that, you can always use other stuff to keep from falling to your death.
As you may already know, there are basically two choices when addressing fall protection from scaffold platforms: a guardrail system and personal fall arrest systems. While not specifically addressed in many safety standards, fall restraint can also be used as a form of fall protection. Other options are available for fall protection from places like open sided floors and roofs, options that include safety nets, monitoring systems, warning lines and fall protection plans. It should be noted that lots of safety folks don’t like some of those options since they require workers to behave and we all know that doesn’t always happen.
Experience has indicated to me that when it comes to fall protection, everybody is an expert. I’m not sure if that is because people fall, making them instant experts, or they think it’s no big deal to “tie off.” So let’s look at some of these issues and sort out the fact from the fiction.
- Fall protection is required when you are more than 6 feet above the level below. Fact and fiction! It depends on the applicable code. Codes require fall protection at heights ranging from 4 feet to 30 feet. So find out what the rule is where you are working (or hanging around).
- Most workers on construction sites, both commercial and industrial, often use personal fall protection equipment. Fiction. Very few workers use personal fall protection equipment.
- Many workers wear personal fall protection equipment. Fact. Luckily very few workers use it.
- Anchors for personal fall protection systems must hold 5,000 pounds. Fiction. If the anchor is designed by a qualified person, it must have a safety factor of 2.
- If you hook your lanyard (the other end of the rope that is attached to your harness) to an anchor, the anchor must be designed. Fact. You cannot guess at the strength of the anchor; if the anchor is not part of a system designed by a qualified person (see #4) the anchor must hold at least 5,000 pounds. Guessing is not allowed although it appears everybody does it.
- The maximum force on the body is limited to 1,800 pounds. Fact. This means you better not fall too far before your fall is arrested. That’s a fancy way of saying that when you reach the end of your rope, the force on your body better be less than 1,800 pounds or there will be two of you. Incidentally, if the force on your body is limited to 1,800 pounds why does the anchor have to hold 5,000 pounds? After all, if you pull on one end of the rope with 1,800 pounds, doesn’t the anchor on the other end only have to pull with a force of 1,800 pounds? Hmmmm-what’s with that?
- The 5,000 pound anchor requirement is based on extensive scholarly research and testing. Fiction. It’s based on the strength of ¾ inch manila rope which is actually 5,400 pounds. It was lowered to 5,000 pounds in the US federal construction standards to agree with the US federal general industry standards. So much for science.
- You cannot free fall more than 6 feet. Fiction (sort of). You can free fall as far as you would like, according to a US federal OSHA Letter of Interpretation. It’s just that when you get to the end of your free fall, the load on your body cannot be more than 1,800 pounds. (Now you know how bungee jumping works.)
- 100 percent tie off is the same as 100 percent fall protection. Fiction. Anybody can do 100 percent tie off; just look at any construction site. Workers tie off to all sorts of ridiculous stuff. Like the guy that ties off to the step ladder he is on! One hundred percent fall protection is easy for scaffold users, but not leading edge scaffold erectors.
- I cannot use a scaffold for an anchor. Fiction. Some scaffolds make very nice boat anchors.
- I can use a scaffold as an anchor. Fact. When designed by a qualified person (and perhaps a qualified Professional Engineer) a scaffold can be used as an anchor for a personal fall protection system.
- It is difficult to provide adequate anchorage for leading edge erectors and still comply with all the fall protection standards. Fact. It’s really tough to get a scaffold to hold 5,000 pounds. It’s really tough to limit the free fall distance for erectors to 6 feet when they have nothing above them to tie to. If we waived certain regulations for scaffold erectors, we would eliminate some of the excuses. For example, is it really necessary for scaffold erectors to have an anchor that can hold 5,000 pounds? Is it really necessary that the system have a 2 to 1 safety factor. After all, as long as he/she doesn’t fall to a certain death have we not succeeded? Something to think about.
- Horizontal lifelines are easy to install and use. Fiction. While they may be easy to install, they are not easy to use. The problem with horizontal lifelines is that people never use them. That’s right; they install them, and hook off but luckily never use them. If they used them they would be terribly disappointed in the performance of the line. There is a reason horizontal lifelines are to be designed by a qualified person. Did you know that an anchor on a horizontal lifeline can see a load of 25,000 pounds if it is not designed properly? What do you suppose that would do to the scaffold?
- All safety consultants and compliance officers are experts in fall protection design and installation. Fiction.
- All scaffold users are experts in fall protection design and installation. Fiction.
- All scaffold erectors are experts in fall protection design and installation. Fiction.
So much for fall protection– I still think the easiest fall protection is: Don’t fall. But then perhaps there’s more fiction in that statement than fact!