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American National Standards Institute Archives | DH Glabe & Associates

Aerial Lift or Mobile Scaffold?

By | Aerial Lifts, OSHA Standards & Regulations, Resources, Scaffolding | No Comments

In the year 2000, at the turn of the century, the U.S. Federal Occupational Safety & Health Administration, OSHA, issued a Letter of Interpretation wherein it opined that aerial lifts known as scissors lifts (see illustration) are not aerial lifts but instead are mobile scaffolds.  The opinion was based on the fact that the revised OSHA scaffold standards for construction reference an American National Standards Institute, ANSI, standard that does not include scissors lifts.  This ANSI standard, known as ANSI A92.2-1969, was written in 1969, before the proliferation of aerial lifts that we have today.

Why was this outdated standard used, you ask?  Well, at the time the review of the original scaffold standard was initiated, A92.2-1969 was the ANSI standard that was applicable.  And since this was the only applicable standard, OSHA was required to work within the constraints of this standard to determine if scissors lifts were aerial lifts or not.  Since scissors lifts were not specifically mentioned in A92.2-1069, OSHA concluded that scissors lifts could not be included in the Aerial Lifts section of the revised standards.  However, OSHA also concluded that scissors lifts are scaffolds and therefore the other scaffold standards apply.  This includes 29 CFR 1926.451-General Requirements, and 29 CFR 1926.452-Additional Requirements for Specific Scaffolds.  Finally, OSHA concluded that since scissors lifts have wheels, they are Mobile Scaffolds and therefore must comply with 29 CFR 1926.452(w)-Mobile Scaffolds.  This interpretation of the standards relies on the accuracy of the assumption that scissors lifts are not aerial lifts and the assumption that scissors lifts are scaffolds.  Accepting these assumptions validates OSHA’s interpretation; not accepting these assumptions results in an entirely different conclusion.

I suggest an alternative interpretation to this dilemma since the industry generally recognizes that scissors lifts are aerial lifts and the Mobile Scaffold standards just don’t apply.  Here’s the argument:  The preponderance of information indicates that it was never intended for scissors lifts to be classified as Mobile Scaffolds.  A review of the preamble to the revised scaffold standards clearly indicates that the writers of the revised standard knew that additional ANSI standards existed: “OSHA recognizes that the A92 Committee has updated A92.2-1969 and has adopted other A92 standards which address technological advances and evolving safe industry practices regarding elevating and rotating work platforms.” (Federal Register, August 30, 1996, p 46095)  Furthermore, the writers also recognized the unique attributes of aerial lifts and the fact that they are just not the same as a typical supported or suspended scaffold.  How do I know that?  Besides stating in the preamble “…that the requirements of §1926.451 and §1926.452 do not apply to this type of equipment,”  the Scope and Application of Subpart L (29 CFR 1926.450(a)) clearly states that “The criteria for aerial lifts are set out exclusively in §1926.453 (Aerial Lifts) of this subpart.”  This exclusion is restated at the beginning of the General Requirements where it is confirmed that “This section does not apply to aerial lifts, the criteria for which are set out exclusively in § 1926.453.”  All this clarifies the applicability of standards but it does not necessarily clarify whether scissors lifts are scaffolds as described in § 1926.451 and §1926.452 or whether they are aerial lifts and consequently must comply with § 1926.453.  I believe the answer to this question exists within § 1926.453-Aerial Lifts and in the preamble for the revised standards.

1926.453-Aerial Lifts includes a note at the end of the section that points the reader to Non-mandatory Appendix C.  This appendix “lists examples of national consensus standards that are considered to provide employee protection equivalent to that provided through the application of ANSI A92.2-1969, where appropriate.”  Appendix C lists seven ANSI standards for aerial platforms, including ANSI A92.6-1990, Self Propelled Elevating Work Platforms. In case you are wondering, that’s the technical description for scissors lifts.  (See the illustration)  Furthermore, the OSHA writers explained in the preamble that “This Appendix is provided to serve as a guide to employers required to provide appropriate employee protection under § 1926.453, Aerial Lifts.  This Appendix reflects the proliferation of equipment-specific ANSI A92 standards since the adoption of ANSI A92.2-1969.”  Looks to me like a scissors lift is an aerial lift, not a Mobile Scaffold.

I can appreciate the constraints under which OSHA must operate.  The rulemaking process requires that the agency must comply with the legal restrictions that are in place to ensure that standards and regulations are not randomly (or intentionally) manipulated.  However, in this case, where it is clear in the industry that a scissors lift is an aerial lift, perhaps a little manipulation might be a good thing.  One last suggestion if I haven’t convinced you:  Read the Mobile Scaffold standards, § 1926.452(w)-Mobile Scaffolds and see how well they apply to a scissors lift.  The first standard requires that the scaffold “shall be braced by cross, horizontal, or diagonal braces, or combination thereof, to prevent  racking or collapse of the scaffold…Scaffolds shall be plumb, level, and squared.”  Does this make sense for a scissors lift?  How about “Where leveling of the scaffold is necessary, screw jacks or equivalent means shall be used.”  Or this one: “Caster stems and wheel stems shall be pinned or otherwise secured in scaffold legs or adjustment screws.”  And finally, “Before a scaffold is moved, each employee on the scaffold shall be made aware of the move.”  If you are operating the controls, do you talk to yourself?

The ANSI standard for scissors lifts, A92.6 is comprehensive, straightforward and very specific to scissors lifts.  Use this document.  You can purchase it directly from the Scaffold Industry Association at a very reasonable cost!

Hot Wheels

By | Fall Protection, OSHA Standards & Regulations, Resources, Scaffolding, Scaffolding Platforms | No Comments

As with all scaffolds, there are design, construction, and safety issues with mobile scaffolds.  The idea here is to discuss some engineering issues, leaving the obvious safety issues to the “competent person, qualified in scaffold construction.”  Now that I think about it, perhaps the safety issues aren’t so obvious so let’s cover those first.  Make sure you have fall protection, falling object protection, access, adequate strength, a decent platform that remains in place, and don’t do something stupid.  Now that we have the safety features in place, proper design, in combination with proper use, makes the mobile scaffold such an excellent productivity tool.

What is it that makes the mobile scaffold safe, or conversely, unsafe?  The center of gravity, an engineering term that describes the stability of a mobile scaffold, is one significant factor.  Another factor is the strength of the casters and other components.  Another factor is the forces required to move the scaffold.  These forces are horizontal, vertical or both.  A qualified designer of mobile scaffolds must consider these factors, and of course the user of the scaffold must understand how to safely drive the scaffold (or at least push it around).

The Construction Industry scaffold standards from the Federal Occupational Safety and Health Administration, OSHA, address these issues as does both the American National Standards Institute, ANSI, scaffold standards and the Scaffold Industry, SIA, Codes of Safe Practice.  Specifically, the federal standards, of which the construction standards are the best source, identify the hazards described above, that is stability, strength, and dynamic forces.

What is the significance of the strength of the various components?  Well, I doubt you want the scaffold collapsing while you are on it.  Therefore you need to know your limitations.  The typical scaffold caster is usually the limiting factor.  Hallway scaffolds, those narrow scaffolds commonly used by drywall installers, have a capacity of about 250 pounds.  Frame scaffold casters, on the other hand, will have a capacity of approximately 500 pounds unless you buy one of those cheap casters of unknown capacity.  Larger frame scaffold casters, and those used with systems scaffolds will have a capacity in excess of 1,000 pounds.  These caster capacities are usually adequate for most mobile scaffold uses and are almost always less than the leg capacity unless, of course, you buy one of those cheap scaffolds of unknown strength.  The bottom line is to find out what your caster can hold before the ball bearings begin to fall out!

The stability of the scaffold is very important to the occupant of the scaffold for apparent reasons.  It’s just not a good idea to have the scaffold fall over, whether it is occupied or not.  How do we ensure that it won’t tip?  By making it big enough and not pushing it over.  If the mobile scaffold has a big enough base, both in width and length, the scaffold will remain standing, absent any other forces.  Except for California, the maximum height to base ratio is 4.  (In California it’s 3 to 1 and no, it’s not because they have earthquakes.)  This means the height can be no more than 4 times the minimum base.  For example, if you have a mobile scaffold that is 5 feet wide by 8 feet long, the maximum height is 5 feet times 4 equals 20 feet.  If you want to go higher, then make the base bigger.  But be careful – you may be overloading the casters because of all that extra scaffold weight.  The sky is the limit, no pun intended, but the higher you go the heavier it gets and pushing it around gets to be a real challenge.

How much does it take to push over a mobile scaffold?  The snappy answer is: not much.  The force needed to move the scaffold horizontally and the force needed to push it over are not the same although the untrained scaffold user may inadvertently be applying a force to knock it over all the while thinking that she is applying the force to move it horizontally on the floor.  Worse yet, if the casters aren’t rolling, due to maybe a small obstruction, a horizontal force at the top of the scaffold will quickly become a force that will knock the scaffold over.  In engineering terms, we call that instability.  For the user who is riding the scaffold down to disaster, it may be referred to in other terms.  Here is what is going on.  When you push against the side of the scaffold, you are trying to get the mass of the scaffold moving.  If you push close to the bottom of the scaffold, all your efforts will go to moving the scaffold.  As you push more, the scaffold slowly begins to move, converting a static (non-moving) condition into a dynamic (moving) condition.  The weight of the scaffold obviously influences the amount of force needed to get the scaffold moving.

Now, another factor comes into play here; the center of gravity.  The center of gravity is an imaginary point in the scaffold that is defined as the center point of all the vertical loads of the scaffold including the scaffold components, platforms, and the folks on the scaffold.  Typically, this point is in the middle of the scaffold but if there are cantilevered platforms the center of gravity will shift towards the direction of the cantilever.  If the cantilever is big enough, or the weight on the cantilever is big enough, or the folks on the scaffold are leaning out over the guardrail, the center of gravity shifts to the outside of the scaffold base, and the trouble begins.  The users get real excited because it is at this point that the scaffold begins to tip.  The same thing can happen when the scaffold is pulled along from the top by grabbing onto the roof trusses, for example.  While it may take a force of say 100 pounds to get the scaffold going, if the bottom isn’t going anywhere and the top is, the center of gravity begins to shift and the force needed to pull the scaffold over reduces to as little as 20 pounds; this is when the scaffold begins to tip.

Right about this time, the errant user has just experienced basic physics and now realizes the error of his ways. He begins to head to the other end of the scaffold in an attempt to makes things right.  Unfortunately he forgot to pin the casters into the scaffold leg and they fell out during the tipping maneuver;  the rest of the story gets real ugly.  And that is why the OSHA standards require that: “Manual force used to move the scaffold shall be applied as close to the base as practicable but not more than 5 feet (1.5 m) above the supporting surface.”  That is also why the standards also require you to pin the casters to the legs.

And what about surfing the scaffold—the technique of “jerking” the scaffold so it moves horizontally?  What do you suppose that does to the forces and stability of the scaffold?

The Standard Standard

By | OSHA Standards & Regulations, Resources, Scaffolding | No Comments

I can answer the one question easily: no, safety standards are not there to make your life more difficult.  The fact is, they are there to make your life safer.  Depending on your age, you may think that they come from ancient history but in reality they are a relatively recent development in workplace safety, going back about 100 years.  The federal OSHA standards have their beginning December 29, 1970 when the U.S. Congress passed Public Law 91-596.  This law required that employers “furnish to each of his/her employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his/her employees.”  That’s fine that Congress says we have to have a safe workplace but what exactly is a safe workplace?  Well, that is where the standards (regulations) come in.  Basically, the standards define what a safe workplace is; the scaffold standards define what a safe scaffold is.  Rather straightforward I must say.  But is it?  Who gets to say what the actual standards are?  Some bureaucrat in Washington, D.C.?  Or, maybe a scaffold association?  How about the scaffold manufacturers?  Just a concerned citizen?  Believe it or not, the answer is:  All the Above!

When the original OSHA standards were developed, they were based on existing codes and standards, primarily the standards developed by the American National Standards Institute (ANSI).  For scaffolding, the ANSI standard that was used was A10.8.  This standard, known as a consensus standard, was developed by devoted manufacturers, users, engineers, safety specialists, and academia.  (This consensus standard still exists today and is updated periodically—the most recent edition is A10.8-2001.)   Basically, the standards are developed by people with diverse backgrounds, expertise, experience, and interests who come together to determine the most effective guidelines for you to use so you are safe while working with and on scaffolds.

For example, last month 40 individuals met to discuss changes to the scaffold standards that are used in California.  The group included scaffold users, manufacturers, suppliers, safety consultants, CalOSHA personnel and designers.  I attended as your representative from the Scaffold Industry Association.   Two intense days were spent debating the plank standards in the California OSHA standards.  Healthy dialogue, a disagreement or two, and finally agreement for changes resulted in updated standards that defined plank used for scaffold platforms.  This is how it works.  While this activity involved only California, the process is similar for other states and the federal OSHA standards.  Basically, no standard can be changed without due process.  While this may seem cumbersome, it is the only reasonable method for developing fair requirements.  Imagine if we didn’t have it.  The standards would very quickly develop into self-serving, non-effective worthless trash.

The process is taken seriously as well it should be.  The government is required to notify us, the citizens, for any changes that are being suggested.  We are invited to comment on any proposed standards that will affect us.  We can do this by writing to the government and/or attending “hearings.”  How long can this process take?  Quite a while.  For example, the federal scaffold standards became effective in November, 1996.  The initial decision that revisions to the existing standards were necessary was made in the mid 1970’s.  That’s right, it took approximately twenty years to revise the standards.  Therefore, the next time you think the standards stink, think about how many hours of work went into what you use every day.

Think about what went into writing these standards.  Dedicated individuals labored over the language and ramifications of their decisions.  Writing standards is not easy; the wrong use of a word, the wrong reference and incorrect grammar have far reaching effects, not only in relation to other standards, but also to you and I who have to apply these standards every day.  The next time you criticize the standards, you may want to pause and consider what you are doing.  Instead, you may want to thank those talented individuals who were watching out for your safety, even if it was back in ancient history!

That Time of Year

By | OSHA Standards & Regulations, Resources, Safety Hazards, Scaffold Components, Scaffolding | No Comments

It is not a healthy or a safe thing when scaffolds fall over.  Consequently, and not surprisingly, there are codes and standards that address scaffold stability and the minimum expectations regarding scaffold stability.  Both OSHA and ANSI, the American National Standards Institute, have minimum standards for the stability of scaffolds.  Simply stated, scaffolds must be secured to an existing substantial structure to make sure they don’t fall over.  While both agencies specify that the connections, or ties, be spaced no further apart than 26 feet vertically and 30 feet horizontally, (20 feet by 30 for scaffolds 3 feet and narrower), the codes are silent regarding the strength or the expected load on the tie.  In some ways the codes are misleading in that they may imply to the untrained worker that the prescribed spacing is both the minimum and maximumspacing of the ties.  In other words, no matter whether the scaffold is wrapped in an enclosure or not, the spacing remains the same.  Such is not the case!

Scaffolds must be designed by a qualified person, basically an individual who knows what he/she is doing.  If the scaffold is going to be enclosed, the qualified person must be familiar with wind forces, velocity, and environmental effects, in addition to other factors.  Where the scaffold is located, the shape of the scaffold, the shape of the structure, whether you are in Chattanooga or Casper, the height of the scaffold, if the windows are open or not, if the scaffold is in the city center or suburbs, and the height of the structure and the scaffold, are all factors that must be considered.  This is not time for guesswork and yet that is exactly what occurs.

One classic approach is to “double up the ties.”  Fortunately this works for a lot of scaffolds, not because it is accurate but because the scaffold erector is lucky.  That’s right, lucky.  Believe it or not, the force on the scaffold can be accurately calculated.  Much research has been conducted by engineers to determine the force of the wind on structures.  Several years ago a horrific accident occurred inChicagowhere a suspended scaffold failed and fell to the street, killing innocent people.  The ensuing investigation determined the vertical force on the scaffold due to the wind was over 11,000 pounds!  This is serious stuff and yes, the forces can be calculated.

Lucky for the scaffold industry, compliance and safety workers generally cannot determine the forces on a wrapped scaffold and consequently cannot determine if an enclosed scaffold is at risk or not.  But this is changing.

pic16-that-time-of-year

Figure 1 illustrates a scaffold at the Air Force Academy that was wrapped.  That area ofColoradocan experience high winds, in excess of 100 mph.  That’s like a Category 2 hurricane.  Is it possible to design a scaffold that can resist this kind of wind?  Sure—look at Figure 1.  Was this scaffold designed on the fly by doubling up the ties and hoping for the best?  No, it was designed by a qualified person, who appropriately applied engineering principles that resulted in a safe design and successful installation.  The bottom line:  Comply with the applicable standards and good construction practice:  Have a qualified person design the scaffold and construct the scaffold according to that design.  (How about that, there are ANSI and OSHA standards that say exactly that.)  So, how much force does the wind exert?

clip_image0021-that-time-of-year

Figure 2 shows an example of the types of forces that can be expected.  Note how the pressure increases dramatically as the wind speed increases.  In other words, at low wind speeds there isn’t much load on the scaffold but as the wind velocity increases, the pressure or force increases much faster.  Notice what happens at 90 mph.  Based on a tie spacing of 26 feet by 30 feet, the load on that tie is 1,625 pounds for an open scaffold but when it is enclosed, that load goes to 22,000 pounds.  That cheap eyebolt you’re using to hold that wire tie just isn’t going to fare well.  You may say that you don’t get 90 mph winds.  While that may be true, you can easily get 50 mph wind gusts and of course, you only need one gust to ruin your day.

What about the second issue, the issue where OSHA considers the enclosure installation as not being a part of the scaffold erection?  This is a sensitive issue.  Basically, OSHA is claiming that the enclosure is not a structural part of the scaffold and thus is not part of the scaffold erection.  Therefore, fall protection, either a guardrail system or personal fall protection system, is required for the enclosure installers; the OSHA Subpart L fall protection standards, 29 CFR 1926.451(g) apply.  However, OSHA chooses to ignore the fact that if a structure is erected solely for the purpose of supporting an enclosure, it is not a scaffold in spite of the fact that scaffold components are used to support the enclosure.  By definition, a scaffold is a temporary elevated platform and it’s supporting structure, used to support workers or materials or both.  If there is no elevated platform, there is no scaffold; the structure is a structure.  OSHA Subpart M would apply in this case.  What do we do?  Stay tuned, we’re working on it.

 

Qualified, Certified or Professional?

By | OSHA Standards & Regulations, Resources, Scaffolding | No Comments

Federal OSHA, as well as the American National Standards Institute, ANSI, has definitions for competent and qualified, particularly as it pertains to scaffolding.  To paraphrase the definition, a competent person is an individual who can recognize a hazard and has the authority to eliminate that hazard.  Furthermore, a competent person is familiar with the OSHA standards regarding scaffolding.  A qualified person, again to paraphrase the definition, is an individual, who by education, training, knowledge, or experience, can demonstrate an ability to solve a problem (in other words, a qualified person is a person who knows what he/she is talking about).   While a competent person is required to inspect the scaffold (identify the hazard), a qualified person is required, not only to design the scaffold, but also to find a solution to the hazard identified by the competent person.  A Professional Engineer is not necessarily required unless the solution can only be done by an individual with the pertinent Professional Engineering knowledge and expertise.

Who determines whether a person is competent or qualified?   For a competent person, it is the employer who determines if an employee is a competent person since it is only the employer who can give the employee the authority.  Of course, it is the employer’s responsibility to determine if the employee can identify a scaffold hazard; this means the employer must be competent – which might be a wrong assumption!

A qualified person obtains his or her qualifications through education, training and experience.  That’s right; we recognize that experience can be a great teacher provided we learn from the experience.  Some do better than others in this area.  Formal education, seminars, on the job training and mentoring also contribute to the level of expertise that develops in each individual over his or her career.  But here is a question to answer:  Who determines who is qualified?  Is it the employer or is it a compliance officer?  OSHA, in the definition, says that the qualified person can “demonstrate an ability to solve or resolve the problem.”  But how do we know the ability if we are not qualified to evaluate that ability?  One way is to ask for verification from the qualified person that indeed he/she is knowledgeable.  This can be through a certificate or diploma.  For example, a certified welder holds a certificate that indicates the welder’s training and abilities.  But suppose the certificate is a fake.  Now what?  What about a scaffold erector who holds a certificate in scaffold erection.  If the individual indicates a propensity for consistently constructing lousy scaffolds, it would be wise to investigate the source of the certificate and determine the qualifications of the certificate giver.  Are there any safeguards against fraud?  The best bet is to accept certificates from only recognized agencies.

This brings us to Professional Engineers.  What is the magic of utilizing the expertise of a Professional Engineer?  None.  What about a qualified engineer—is this the same?  No.  A Professional Engineer’s credentials are your assurance that the individual has the qualifications to solve the problem at hand.  An engineer cannot be called an engineer without the proper education and testing to verify knowledge.  Each state in theUnited Statesand each province inCanadahave Boards of Registration that verify the legitimacy of Professional Engineers.  An engineer, while he or she may hold a degree from a university, cannot be called a Professional Engineer without further training under the supervision of a licensed engineer and successfully passing licensing tests. Provinces and states also require continuing education on an annual basis to ensure an engineer’s expertise.  A Professional Engineering Seal on a scaffold design is your indication that the design was conducted according to accepted engineering standards and that the design is safe.  (This doesn’t necessarily mean the scaffold is safe since it is the “competent person, qualified in scaffold erection” who must make sure the scaffold is constructed according to the design.)

Some people think the seal is provided to help spread the liability.  Nothing could be further from the truth.  The laws and Code of Ethics for Professional Engineers require that Professional Engineers only practice in their areas of expertise.  This means that the engineer involved with scaffold design shall be qualified and have expertise in scaffold design.  License suspension and revocation are the remedies for engineers who do not adhere to these and other high standards of the profession.  Related to this are people who fraudulently hold themselves out as Professional Engineers; fines and imprisonment await these pretenders.  Finally, what is the difference between a qualified engineer and a Professional Engineer?  None, except that the Professional Engineer has a license to practice engineering.  Other facts that should be understood include the fact that if you are not an engineer you cannot legally say you are “engineering a design,” nor can you say you have an engineering department unless you have a Professional Engineer on staff.  An engineered scaffold layout is exactly that:  a layout completed by a Qualified Professional Engineer.

Scaffolding is a serious business.  That’s why we look to competent and qualified individuals, including Professional Engineers, to design and inspect scaffolds.

Imagine

By | OSHA Standards & Regulations, Resources | No Comments

Imagine a scaffold industry without rules and guidelines.  Imagine that you could do anything you wanted with a scaffold.  Imagine a scaffold industry without OSHA or ANSI.  (I’ll bet a few of you could easily imagine that!)  Imagine that you had no idea how to use a scaffold safely.  Imagine nobody cared about your safety.  Imagine a scaffold industry without dedicated people.  If you can imagine any of those things, then you probably cannot imagine that a dedicated group of men and women convened in Long Beach California in July to do what many cannot imagine:  promote the safe use of scaffolding, advance the knowledge base of the business of scaffolding, and yes, develop guidelines, codes, training materials, and methods to help you use the product of scaffolding in a safe manner.

And wait, there’s more!  These same dedicated folks work with the very organizations that set regulations and rules that govern this scaffold industry.  Now, if you don’t like this kind of relationship, then you are in the wrong company of individuals.  Simply stated, because of the Scaffold Industry Association (SIA), you have workable standards.  Because of the SIA, you have guidelines for the safe use of scaffolding.  Because of the SIA, you have fall protection representatives talking with scaffold people who are talking with scaffold users.  Because of the SIA, scaffold users are talking with industry experts and getting advice on the proper use of scaffold products.  And the best part of all this is that these dedicated folks, who have worked hard on your behalf have done it because they get paid — nothing!

That doesn’t make any sense, somebody doing something for nothing.  But that’s what was going on at the Long Beach Convention.  And it goes on all year.  Look at some of the specifics:  The Supported Scaffolds Council is producing a presentation that you can use to train your employees and customers on the safe use of scaffolds.  Similarly, the Suspended Scaffold Council has also produced an excellent presentation that you can use to train your employees and customers on the safe use of suspended scaffolds.  The Plank Council has done the same for you.  All of this is done without any financial compensation.  That, frankly, is pure dedication.

The upside on all this effort is a safer and more productive work environment.  The association also works with the code and standard writing agencies, representing your interests and ensuring that the codes and standards that are developed reflect the best intentions and requirements of all interested parties.  For example, the SIA is the secretariat for the American National Standards Institute (ANSI) committees that develop the consensus standards for aerial platforms.  The SIA has been involved with the ANSI committee for scaffolds for many years, protecting your interests and helping in guiding the committee in developing effective guidelines.  SIA has participated with federal and state Occupational Safety and Health Administrations (OSHA) for decades; that participation continued in Long Beach where a safety conference was held.  California OSHA representatives participated in a panel of experts who answered questions and explained policy.  This is indicative of the type of work that is being done for you and the industry.

At the Long Beach convention, you had the opportunity to talk to manufacturers and suppliers of scaffolding products and services.  These exhibitors illustrated the essence of the business, the vibrancy and future of the business.  Many exciting new developments could have been viewed and inspected, from new scaffold innovations to software that improves your productivity to safety products that impact the welfare of your employees.

Finally, there is one important aspect that you may not have seen had you attended the convention. It’s what I like to call the invisible operators.  This essential group of individuals includes the Board of Directors, the Executive Committee and the SIA staff.  This is the behind the scenes activity that steers the association and makes it function. The dedication of the members to the cause drives the association; individual participation and expertise sustains it; new ideas propel it to new expectations.  The results were apparent at the Long Beach convention.  This is what your association does for you. Thanks for being part of it.

Must We Inspect?

By | OSHA Standards & Regulations, Resources, Scaffolding, Uncategorized | No Comments

An explanation of the intent of the OSHA scaffold inspection standard

 

According to certain authoritative sources, scaffolds shall be inspected for defects.  You ask yourself, why should it be necessary to inspect a scaffold?  After all, if the scaffold erector is any good, shouldn’t the scaffold be perfect in all aspects and therefore be safe to use?  Right, and nobody gets injured or killed while using a scaffold!

 

The federal Occupational Safety and Health Administration, OSHA, (one of those authoritative sources,) clearly specifies in Construction Standard 29 CFR 1926.451(f)(3), that “Scaffolds and scaffold components shall be inspected for visible defects by a competent person before each work shift, and after any occurrence which could affect a scaffold’s structural integrity.”  This is an interesting statement in that there are several key requirements worth further clarification, particularly since readers of the standards tend to interpret this particular standard in a multitude of ways.

 

Before trying to interpret anything though, assuming that interpretation is even necessary, let’s look at the individual specified in this standard, the “competent person.”  In brief, OSHA identifies a competent person as an individual who can identify a hazard, and has the authority to do something about it.  The longer version expands that definition and requires the competent person to be familiar with the scaffold standards and with typical scaffold hazards.  Does this not suggest that the competent person be familiar with the scaffold standards?  Of course it does.  Unfortunately, too many of us compare industry longevity with knowledge.  In other words, since I’ve been involved with scaffolds for thirty years, I know everything about scaffolds.  The flip side to this is the assumption that since I read (and somewhat understand) the scaffold standards, then I know everything about scaffolding.  Fortunately, being a competent person is more than reading the standards or working with scaffolds for thirty years.  In other words, you have to work at being a competent person.  You truly must understand the hazards; in fact, you must be able to identify those hazards because others are expecting and relying on you, the competent person, to evaluate the scaffold and verify that it is safe.

 

Having clarified the issue of a competent person, the one issue in this standard that raises so many questions is the requirement that scaffolds be inspected “before each work shift and after any occurrence which could affect a scaffold’s structural integrity.”  What is a work shift?  What is an occurrence?  Is it only in the morning?  What happens at the refinery where there are multiple work shifts and multiple scaffolds?  How often does an occurrence occur?  We sure can play games with this one, can’t we?  To determine what the standard is all about, we must look at theintent of the standard by asking the question: What hazard is OSHA addressing in this standard?  What can happen if the scaffold in question is not in compliance?  The answer is straightforward: Don’t use unsafe scaffolds.  But how do we determine if the scaffold is safe?  Hey, that’s where the competent person comes in!  Before anybody gets on the scaffold, as in at the start of the work shift, the competent person should ask if the scaffold is in compliance with the standards.  Are there any hazards with this scaffold that will expose the user to injury or death?  Let’s face it.  Who cares if it’s the beginning, the middle, or end of the work shift.  Let’s not kill the user.

 

The bottom line on this standard is the simple fact that we want scaffold users to use only safe scaffolds.  To achieve this goal, OSHA, and other agencies, such as the American National Standards Institute (ANSI), have required that scaffolds are to be inspected at sufficiently frequent intervals, by competent people, to ensure that the scaffold is safe.  Furthermore, OSHA also requires that users, that’s right, users, are sufficiently trained to recognize scaffold safety hazards.  Frankly, users are expected to know enough about scaffold hazards before they get on the scaffold so they stay out of harm’s way.  There is no magic here.  Unfortunately, it’s common sense that seems to get lost in the regulation.  Make sure the scaffold is safe.  If this means inspecting a scaffold three times a day, so be it.  If it means inspecting it every hour, so be it.  And when you inspect it, you must know what you’re looking for, using your ability to identify the hazard, and your authority to do something about it.