OSHA Standards & Regulations

Pop Quiz: 30 Questions About Scaffolding

By | Blog, OSHA Standards & Regulations, Scaffold Bracing, Scaffold Components, Scaffolding, Scaffolding Planks, Scaffolding Platforms | No Comments


It is somewhat surprising how creative workers can get when it involves scaffolding.  Just when it seems all the questions have been answered, along comes a question that raises an issue that was never addressed.  Challenge yourself to these questions and see if your answer agrees with the one given at the end of this article.

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Fall Prevention on Your Commercial Construction Site

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fall-prevention-commercial-constructionIn 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.

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4 Reasons Contractors Need Their Own Structural Engineers on Their Projects

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When designing a construction project, few people realize that the designer often cannot answer common questions that arise during the construction process. The owner’s structural engineer, better known as the engineer of record (EOR), is hired primarily to design the project, but after the plans have been approved, the EOR does not get involved with the means and methods the contractor uses to deliver a finished project. This often leaves contractors flying blind, so to speak, as many times the plans contain errors or lack sufficient instructions. For these reasons, it is a good idea for contractors to hire their own, independent structural engineer, known as a contractor’s engineer.
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Fall Protection – The Full Package

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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.
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Solid Platforms

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It is true that a scaffold without a platform cannot be a scaffold since a scaffold is defined as a “temporary elevated platform and its supporting structure.” It can, therefore, be assumed that a platform is rather important. But it isn’t the OSHA standards, or any other regulations and guidelines that make a scaffold platform important; it is the absolutely critical nature of a platform that makes it imperative that scaffold designers, erectors, and yes, users fully understand what makes a scaffold platform safe for use. So, what makes a platform safe and how is its safety assured prior to placing the platform and its supporting structure to use? Let’s explore those issues through a series of frequently asked scaffold platform questions:

What materials can be used to construct a scaffold platform?
Anything can be used to construct a platform. Common materials included solid sawn wood members, manufactured wood products, aluminum, steel, fiberglass and plastic. In fact, even cardboard and concrete could be used although I doubt the erectors would appreciate installing concrete panels!

If solid sawn lumber is used to construct a platform, does it have to be “Scaffold Grade”?
It depends. Some standards, such as the U.S. Federal OSHA General Industry Standards, 29 CFR 1910, require the use of scaffold grade plank while the U.S. Federal OSHA Construction Industry Standards, 29 CFR 1926, do not. When designing for a construction industry application, if you are a qualified designer who can calculate lumber stresses and control the loads that will be applied to the lumber, then you can specify any wood you desire provided the lumber maintains a safety factor of at least 4 [29 CFR 1926.451(a)(1)]. Having said that, the Scaffold & Access Industry Association, SAIA, the Scaffold, Forming & Shoring Institute, SSFI, and industry professionals encourage the use of scaffold grade plank when using solid sawn lumber.

Do all planks have to extend (overhang) their supports by 6 inches minimum and 12 inches maximum?
No. If the plank is secured from movement so that the individual plank cannot slide off its support, it does not have to extend a minimum 6 inches over its support. Conversely, it can extend further than 12 inches (in some jurisdictions the maximum overhang is 18 inches) if the plank is secured from movement, including uplift. Of course the plank has to be designed so the use of a long overhang doesn’t result in an overstressed plank.

Which jurisdictions allow an 18 inch overhang?
If you are a scaffold designer, erector, inspector or user you should know the answer to this question. If you don’t know, get training for your jurisdiction. For example, federal OSHA allows overhangs up to 18 inches for plank longer than 10 feet, California allows 18 inches for any length plank and the US Army Corps of Engineers limits all plank overhang to 12 inches, regardless of plank length.

I have been told that nailing plank damages them. Can you nail plank together to keep them from moving?
Of course you can—its wood! If you pound in the nail in the same spot for a long time you’ll probably damage the plank but you really have to keep hammering it.

Is it true that you cannot install plywood on top of plank?
No. While at one time US federal OSHA issued a Letter of Interpretation (LOI) that claimed that you could not install plywood on top of plank, it was rescinded (the LOI went away). Keep in mind that once plywood is installed on top of plank, the plank become “joists” just as 2×4’s or 2×10’s (plank standing on edge) would be.

Speaking of joists, what can be used to support a plywood deck?
You can use whatever works. That doesn’t mean slapping down whatever is available—it means anything that works; any structural member that is designed by a qualified person (see US federal OSHA standard 29 CFR 1926.451(a)(6)) can be used. This includes solid sawn lumber, laminated veneer lumber, aluminum joists, steel beams, and tree trunks if you can figure out how strong they are.

Can I use balsa wood?
Sure, as long as it has the sufficient strength.

US federal OSHA specifies that a platform cannot deflect any more than 1/60 of the span when loaded. [29 CFR 1926.451(f)(16)] Does this apply to the typical manufactured plank that is made out of aluminum and has hooks on each end for hooking over its supports?
You it does. However, based on my experience, if your 10’-0” aluminum platform unit deflects 2 inches due to the load, you may have a serious overload problem.

A common practice is to install a “skip plank” platform where the plank are spaced at about 19 inches on center, resulting in a platform where every other plank is removed. This of course is covered with plywood and requires only half the plank to construct the platform. It has been claimed that a skip plank platform is as strong as a fully decked platform, especially because it seems to not deflect as much. Is this true?
How can it be as strong if it has half the plank? It just seems that way because the plywood helps to distribute the load to more than one plank, making it feel stronger. Don’t fool yourself—it is half as strong. Actually it is less than half as strong since the plank have to support the plywood.

You have mentioned plywood several times now. What thickness plywood is needed for a scaffold platform?
I cannot answer that. It all depends on the members supporting the plywood and the spacing of those members. Remember, and this is important, just because the plank supporting the plywood span 10 feet, doesn’t mean it is a “light duty scaffold.” Your platform must be designed by a qualified person, a person who knows how to calculate loads, use charts accurately and/or have the ability to “solve the problem.”

Can particleboard, oriented strand board (OSB) or flake board be used as a platform?
Sure. See the answer above about designing platforms.

Is there such a thing as an “OSHA approved plank”?
Nope. OSHA doesn’t approve any product. It is up to you to use the plank properly. If you don’t know how to do that, get some training.

Scaffolding Scores High – Unfortunately!

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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.


1.     Fall protection  (c)
2.     Hazard communication
3.     Scaffolding  (c)
4.     Respiratory protection
5.     Ladders  (c)
6.     Powered industrial trucks
7.     Lockout/tagout
8.     Wiring methods
9.     Machine guarding
10.  Electrical: systems design

C = Construction standard
Figure 1


Unknown Knowns

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It seems that speculation runs rampant at the beginning of every year as forecasters speculate about the economy, markets, jobs, stability and politics. Along those lines, it is time to speculate about the future safety of the scaffold and access industry. More specifically, will scaffolding still rank up there in the OSHA top 10 list of citations at the end of 2015 or will the industry somehow miraculously alter the trend? More importantly, is scaffold safety accurately measured by using the OSHA Top 10 as a reference?

It is generally accepted that OSHA regulations address hazards. Take, for example, the requirement that all extension ladders must extend at least 3 feet (0.9 m) above the upper landing surface. The hazard here is that the worker loses stability while exiting or accessing the ladder. Infractions of this regulation are often cited and consequently show up on the OSHA Top 10 list of citations, suggesting that employees are frequently injured and killed because the ladder doesn’t extend 3 feet above the landing. Since the hazard is a lack of a handhold as the ladder user exits or accesses the ladder, can it be reasonably assumed that the lack of the ladder extension always results in injury or death? Can the correlation be made that the number of citations equals the severity of the hazard? Or is there another explanation that has very little to do with the hazard?

Using the ladder regulation as the example, it is my opinion that the number of citations has more to do with the ease of identifying a violation of a given citation than it is has to do with the severity of the hazard. While it is true that losing your grip while exiting a ladder can result in an injury or even death, it is also true that it is very easy to identify whether a ladder is extending 3 feet above the landing surface or not. In fact you can probably spot this violation while driving down the street. It’s a no-brainer citation. On the other hand, how many citations have been written for a safety factor (29 CFR 1926.451(a)(1) violation where it takes some analysis and calculations to determine if a violation occurred?

The same “no-brainer citation” argument can be used for guardrail systems, particularly on scaffolds. A quick look at a scaffold will determine if the guardrail has been installed. Bingo – another easy citation! This is not to say that fall protection regulations should not be enforced, especially since falls in construction are a leading cause of injuries and death; rather guardrail violations are easy to identify and therefore it is not surprising that guardrail violations consistently show up on citation lists.

Donald Rumsfeld, former U.S. Secretary of Defense said it best: “There are known knowns. There are known unknowns. There are unknown unknowns. But there are also unknown knowns. That is to say, things that you think you know that it turns out you did not.” The secretary’s wise words of wisdom can be applied to the subject at hand. The known known is the number of citations. But wait; there is an unknown known. The number of citations does not necessarily indicate the severity of the hazard but rather the number of citations for a specific regulatory infraction. Frankly, I think it indicates the ease of citation. If a worker falls from a scaffold, it is typically concluded that the lack of fall protection is to blame. But is it? Was the investigation sufficient to warrant such a conclusion? Were the investigators qualified to make such a determination?

Because the OSHA “Top 10 most frequently cited OSHA standards violated” list is commonly used to evaluate the safety of a specific sector of the industry, and because scaffold citations always appear in the Top 10, scaffolding is frequently perceived as a dangerous product in a dangerous industry.   Perception leads to faulty conclusions which of course leads to more faulty conclusions. The Top 10 list can be dangerous if not used properly.

Consider this: Federal and state OSHA has approximately 2,200 inspectors who did 89,664 inspections in 2013. (41 inspections per inspector—not quite one per week on average.) Federal OSHA did 39,228 of those inspections utilizing a budget of $535,246,000.00 to do so, or $13,645.00 per inspection. Are we getting our money’s worth? It is very important that first, citations are accurate and secondly, they stick. That is, the employer agreed to the fine and/or the validity of the citation. Just because a citation was issued doesn’t mean it was a valid citation. Many citations are unwarranted and never result in a fine or agreement by the employer that a violation occurred. Unfortunately this may not show up in the Top 10 List, leading to faulty conclusions.

So, here are the known knowns: Worker deaths have decreased from 38 deaths a day in 1970 to 12 a day in 2012 – that’s good. The bad news is that in construction, 796 workers died in 2013; that means 3 workers in construction died per day! 294 of those deaths were from falls. Here are the unknown knowns: How many falls were from scaffolds? And then there are the unknown unknowns: What were the dead workers doing before they decided to fall to their deaths? Was it a faulty scaffold? Was it an untrained worker? Was it suicide or murder? Was it work related? Was it the employer’s fault? Was it the employee’s fault? Was it a design error (scaffold designer’s fault)? Was it a scaffold supplier error? Or was it an unknown unknown because “things that you think you know that it turns out you did not”? And to think that we know! By the end of 2015, we will know the number of citations (the known known) but will we know the unknown? If history is any indicator, probably not; don’t let statistics be the sole criteria; as the saying goes: “It’s what you don’t know that will kill you.” According to Secretary Rumsfeld, it appears that would be the unknown unknown.

Statistics in this article came from OSHA and can be found at

OSHA as Insurance

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Insurance is a big deal.  There’s life insurance, medical insurance, insurance for insurance (reinsurance) and scaffold insurance, to name a few.  Generally, the purpose of insurance is to reduce financial risk for an individual entity; frankly, another way to look at it is that insurance shares the risk with other similar individual entities.  For example, life insurance works for both the insurer and the insured because we don’t all die at the same age.  Scaffold insurance works because not all scaffold companies are having accidents all the time.  Actuaries use data to determine the risks involved for the activity.  If the actuaries get it right, the insurance company makes money and the insureds are protected against disaster.

What if OSHA could be reorganized as an insurance company?  Now, don’t laugh—well not yet anyway.  Let’s see how this might work, using the insurance industry as a model.  Insurance companies evaluate the risk of the activity, determine the cost, and establish a rate to charge the client.  If general liability insurance is the product, the insurance company will look at the costs that companies incur doing business.  For scaffold companies, it will include accidents, lawsuits, injuries and deaths.  Once the risk is established, an adequate premium is determined to make sure the insurance company doesn’t lose any money.  However, taking the same model and applying it to OSHA standards and more importantly, to violations and citations, requires some manipulation and imagination.

Here’s how it would work.  Consider OSHA as the insurance company and the scaffold company as the insured.  Each year a scaffold company would invite OSHA onto any number of its projects for an inspection.  If there are no violations of the applicable OSHA standards, the company would get credit points.  We could call the credit points “OSHA bucks.”  These OSHA bucks would be insurance against future inspections that OSHA does without announcement, like they do today.  A scaffold company could bank these OSHA bucks similar to an insurance policy.  For example, assume a scaffold company has a general liability policy valued at 2 million dollars.  It could similarly bank 2 million OSHA bucks to be used in the future.  If OSHA shows up on a job and finds a violation, the scaffold company would pay the fine with OSHA bucks.

There probably would be a question about how many bucks a scaffold company could get.  Right now the way the system works is that if there is a single violation, the scaffold company wins a citation and gets to pay a hefty fine.  For example, on a scaffold that has a thousand guardrails, if only one guardrail is missing, the company fails the test and is cited.  Therefore, it is only fair that a buck should be given for each component of the scaffold.  If the suspended scaffold has 749 components there are 749 bucks in play.  Conversely, if an investigation of the scaffold reveals that only one component is missing, then OSHA is only entitled to one buck.

Actually, this system could be advantageous to the entire industry.  OSHA bucks could be traded between scaffold companies.  For example, scaffold company A, which constructs really good scaffolds, could trade OSHA bucks for some real money from company B which just can’t seem to build scaffolds correctly.  Contrary to the present system where OSHA can bargain away the monetary value of an impending fine, under this new system OSHA would not be allowed to trade bucks; in fact they wouldn’t have any bucks in their possession for trading.

To make the concept legitimate, there would have to be referees to make sure both the employer (scaffold company) and OSHA were behaving.  The referees would be independent, objective individuals who have a thorough understanding of scaffolding and the standards.  They would be paid by both the scaffold company and OSHA so that there would be no question about fairness.  Alternatively, these referees would be paid by the “loser”, that is, either the scaffold company who does have a violation, or OSHA if there are no violations.

You don’t think this is a good idea?  Here are a few advantages of such a system:

  1. Every time OSHA is invited onto a project, the individual Compliance Safety & Health Officer (CSHO) would learn about correctly constructed scaffolding.  (It’s assumed OSHA wouldn’t be invited onto a jobsite if the scaffold wasn’t correct.);
  2. Scaffold company employees would learn how to construct scaffolds correctly since an inspection is known to be occurring;
  3. CSHO’s would have to know their stuff;
  4. Scaffold companies would have to know their stuff since CSHOs would know their stuff;
  5. Informal hearings, formal hearings, and trials would be abolished;
  6. Ridiculous citations would be eradicated;
  7. Preposterous scaffold company claims would be eliminated;
  8. Resources would be spent on prevention, not enforcement and defense.

Just think how exciting this would be; instead of OSHA being the sheriff, as declared by the Department of Labor several years ago, employers, employees and OSHA would live in harmony since they all would realize that there are some big OSHA bucks at stake.  Of course, the current situation involves some very serious money too.  Unfortunately, it’s the employers that are handing out the money when the citations are unwarranted citations, brought on by inadequate understanding of the standards and scaffolding.  Unfortunately, there is no insurance for that.

Federal OSHA 29 CFR 1926.451(c)(2): Foundations and Swivel Jacks Clarification

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The following is a clarification of OSHA Standard 29 CFR 1926.451(c)(2)(i) which requires that: “Footings shall be level, sound, rigid, and capable of supporting the loaded scaffold without settling or displacement.”

This standard addresses the hazard of a foundation that is insufficient to support the scaffold.  The intent of the standard is to require that scaffold foundations are adequate; that is, they have sufficient strength, are stable, and the footing compensates for non-level surfaces that can introduce horizontal forces which have not been restrained.

The claim has been made that swivel screwjacks cannot be used with scaffolds since they bear on non-level surfaces.  This claim is incorrect since the screwjacks are being used to create the level surface that the standard requires.  While it might be argued that the screwjack is part of the scaffold and consequently must bear on a level surface, this argument is without merit for the simple fact that the swivel screwjack is specifically used for the purpose of bearing on sloped surfaces.

Standards have never precluded the use of swivel jacks with scaffolds.  The truth is quite the opposite: swivel screwjacks are used to create the level surface that is required so that scaffold legs are stable.  Interestingly enough wedges and shims are also used to create a level surface.  By disallowing swivel jacks, it can be argued that wedges and shims cannot be used since they are not part of the foundation but rather are a part of the scaffold.  In other words, if it were not that the scaffold is at a specific location, the wedges and shims would also not be there.

In summary, swivel jacks are a permissible component to be used in the construction of a scaffold.  As with all scaffolds, the scaffold shall be designed by a Qualified Person who will address the issue of horizontal forces when designing the foundation.