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ANSI Archives | DH Glabe & Associates

Up and Down – And Around Too!

By | Mast Climber, OSHA Standards & Regulations, Resources, Scaffolding, Scaffolding Platforms | No Comments

Mast Climbing Work Platforms are marvelous pieces of equipment.  And safe too, provided you behave yourself.  Actually it isn’t very difficult to use these platforms—provided you have been trained.  That isn’t unusual.  After all, if you want to use any scaffold or aerial platform you have to be trained.

Mast Climbing Work Platforms are Aerial Platforms.  That is, they are a unique type of aerial platform, designed to provide access at heights.  Aerial platforms include nine types of unique platforms including “Boom Supported Elevating Work Platforms,” commonly known as cherry pickers or boom lifts, “Self-Propelled Elevating Work Platforms,” also known as scissors lifts, and “Vehicle-Mounted Elevating and Rotating Aerial Devices.”  These are commonly used by power companies and typically have a boom and basket mounted to a truck.  Mast Climbing Work Platforms, as the name suggests, has a platform that is supported by a mast or masts, depending on the design of the platform and the length of the platform.  The platform rides up and down the mast by hydraulics or motors.  The platform is enclosed with a guardrail system and access can be by ladder or direct access to the building.  These machines are rather robust in that they carry substantial loads to great heights.  As I said earlier, if you behave yourself, these platforms pose no hazards to the user.

The US federal OSHA construction standards that apply to aerial work platforms are found exclusively in 29 CFR 1926.453.  Unfortunately, the OSHA standards are not clear or very effective.  Since mandatory OSHA standards cannot reference non existing consensus standards, the only ANSI standard that was available at the time the revised scaffold standards were promulgated was ANSI A92.2-1969.  That was a pretty long time ago.  And back then there was not the plethora of aerial platforms that we have today.  To compensate for this deficiency, OSHA provided Non-mandatory Appendix C which lists ANSI standards that are more current.  Furthermore, OSHA states in 29 CFR 1926.453 that “Non-mandatory Appendix C 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.”  If you have ever read A92.2-1969, this is the understatement of the year.  Your best bet is to use the applicable ANSI standard and not worry about 29 CFR 1926.453.

So, what is in the ANSI standards that make them so much more effective?  First, each of the standards is specific to the type of aerial platform you are using.  For Mast Climbing Platforms, A92.9 is very specific in the obligations and responsibilities of the various parties who are involved with these machines.  For example, there are requirements that manufacturers must meet in the design and manufacture of the machine.  The company renting the equipment must meet requirements that are specific to their part of the work.  And of course, the erectors and users must have training.

As a user of a mast climbing platform, you must understand the safety issues including fall protection, falling object protection and access to mention a few.  The user must also understand the loading limits and criteria for the platform being used.  A single mast platform, that is a mast climber that has a platform supported by only one mast, must be loaded carefully so that the load isn’t out of balance due to the platform cantilever on both sides of the mast.  That doesn’t mean that a two mast platform can be loaded any way you want; you need to know the limitations no matter whether it is a single or two mast platform.  Guardrails can be removed so the platform can be loaded.  This means the user must utilize personal fall protection or restraint equipment while exposed to a fall.

Erectors require a deeper understanding of the equipment.  The base of the mast climber must set on a firm foundation.  It is not uncommon for the mast climber to set on a roof or upper floor of a building.  When this occurs, the supporting structure must be analyzed for capacity.  Don’t guess on this; get a qualified engineer to help you.  Mast climbing platforms can be free standing for a certain height, depending on the base and the design.  However, there is a limit to how height they can free stand, typically in the range of 25 to 40 feet.  Once the mast exceeds the design limit for a freestanding installation, the mast must be secured, or tied, to the adjacent structure.  These ties are not your typical #9 wire but rather are a structural connection that has to support a considerable load.  As a matter of fact, they are critical to the safe operation of the climber.  If you are not an erector, don’t even think about messing with the ties.  If you are an erector, make sure you understand that the first tie must remain connected until a crane is connected to the mast or the mast is otherwise stabilized to prevent tip over.

So what else can go wrong?  Let’s see, besides the mast falling over, workers have climbed up and over the guardrail in an attempt to climb onto an adjacent building floor.  Workers have bypassed the safety switches and run the platform off the top of the mast.  Workers have overloaded the platform to the point of wearing out the gears and rollers and just plain knocking the platform over.  Suppliers have not properly maintained the platform before renting it to the end user.  And, the end user has not maintained it in the field.The solution to all this is easy.  Know what you are doing when you use mast climbing platforms.  If you haven’t been trained don’t get on one.  If you aren’t trained in the proper assembly and disassembly keep your hands off.  Don’t rely on the OSHA aerial platform standards for an education; they won’t help you.  Go to the ANSI Standards and get the training.  In fact the SIA can help in the training!

New Developments

By | Aerial Lifts, Mast Climber, OSHA Standards & Regulations, Resources, Safety Hazards, Scaffolding | No Comments

I’m no genius and I am not a psychic but hey, I can spin a good story as well as anyone.  I will focus on what I know and what I’ve seen (that’s where a knowledge of the past is handy) and give you my opinion about the effect of new developments.  When one thinks of the scaffold frame, its tough to get excited about a 70 year old product.  It’s even tough to get excited about systems scaffold which, relatively speaking, is a new product in comparison with the scaffold frame.  Suspended scaffolds probably have the edge on new developments as far as traditional products go but even there we are still hanging around when we are using them.  Mast climbers, scissors lifts, boom lifts and similar mechanized devices are probably the biggest change in the industry in the past 25 years and will have the biggest impact as far as new developments.

Actually, the new developments I think are not with the specific products but rather how they are used more efficiently.  Additionally, developments in safety standards application will be a bigger development than the actual product.  Let’s take a look at how the safety standards, including the OSHA and ANSI standards, are affecting and will continue to affect the development of the industry.  You may think that this is not a “new development” but it is because of the evolution of standards and the agencies involved with their enforcement.  If the past is any indicator, and I think it is, this industry will continue its slow apathetic spiral downward, capitulating at every turn to ever stricter standards.  While this appears contradictory to the activities of the Scaffold Industry Association, especially in light of the wonderful developments at the recent Committee Week, I specifically address your attention to the willingness of scaffold industry workers to submit to safety officials who know little of the industry but have great authority.

Often I hear a scaffold company owner defer to OSHA, for example, because he/she does not want to make the effort to learn the subject matter.  I’m not ripping on OSHA or any safety people here; they are only filling the void left by lazy scaffold workers.  If you think I’m off base here, I politely ask you to think about your experience with OSHA and other safety workers.  Invariably, the experience always seems to be less than comfortable.  Why is that? Is it because they don’t know anything or is it because you don’t?

About this example:  For years a regulation has existed that requires all scaffolds have a safety factor of 4.  This means that the scaffold must be 4 times stronger than the load that will be put on it.

You cannot change what over, only where you go.

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.

Adjustable Scaffolds–What is it?

By | Aerial Lifts, Fall Protection, Mast Climber, OSHA Standards & Regulations, Resources, Scaffolding, Scaffolding Platforms | No Comments

While scaffolds come in all shapes, sizes, and function, they can be categorized as supported, suspended or aerial lifts.  The American National standards Institute, ANSI, has defined an aerial platform as “a mobile device that has an adjustable position platform, supported from ground level by a structure.”  Scissors Lifts, Mast Climbers, and Boom-Supported Elevating Work Platforms (Boom Lifts) are examples of these machines.  While that may explain aerial lifts, what is the difference between supported and suspended scaffolds?  OSHA offers a rather detailed description for each but it can easily be explained this way.  A suspended scaffold is any platform supported by ropes.  That means all other scaffolds are supported scaffolds (if they aren’t aerial lifts).  In other words, a two point wire rope suspended scaffold really is a suspended scaffold.  However, a frame scaffold hanging off the side of a bridge, for example, is a supported scaffold, even if it is “suspended” over the side of the bridge.  While this example may be obvious, other scaffolds may defy easy categorization.

An Adjustable Scaffold is one of those scaffolds.  Which standards apply to this scaffold?  Is an Adjustable Scaffold a supported scaffold or is it a suspended scaffold?  For that matter, what is an Adjustable Scaffold?  By definition, an Adjustable Scaffold is “a scaffold structure with a manually elevating carriage that supports work and material platforms.”  What confuses the situation is that the platform on an Adjustable scaffold is supported by wire ropes.  This would mean that the scaffold is a suspended scaffold.  But not so fast; the wire rope is supported by rigid legs. That would make it a supported scaffold!  Looks to me like it’s both suspended and supported.  Well it is, sort of.  An Adjustable Scaffold is classified as a supported scaffold and here is why.  It is true that all Adjustable Scaffold platforms are supported by wire ropes.  However, unlike the typical suspended scaffold, Adjustable Scaffolds have an additional mechanism, a back-up system if you will, that supports the platform if the wire rope fails.  This mechanism includes a mechanical lever that prohibits the platform from falling very far, typically less than 12 inches.  Because this mechanism exists, the Adjustable Scaffold is not a true suspended scaffold.  That is, if the rope breaks, the scaffold platform will not crash to the ground.  Rather, it will only drop 12 inches, terrorizing the occupants but otherwise staying in the air and keeping them safe.

 

adjustable-scaffold

 

Adjustable Scaffolds are used almost exclusively by brick masons.  The ability of the platform to be slowly raised as the brick wall is constructed permits the top of the wall to always be at the optimum elevation for the mason.  One of the unique features of some Adjustable Scaffolds is the ability to free stand 28 feet high.  This allows the scaffold to be erected to the full height of a “big box” store (e.g. a Home Depot® or Wal-Mart®) without having to tie it to the structure.  This is a big advantage for masons in terms of efficiency and constructability.  For taller scaffolds, the masts must be tied to the adjacent structure, in compliance with applicable supported scaffold criteria.

As with all scaffolds, Adjustable Scaffolds must have proper fall protection.  This usually is a guardrail system that is installed when the scaffold is initially erected.  However, when the platform is being stocked by a forklift, and the guardrails are removed, the exposed employees must be wearing fall restraint or arrest equipment attached to a suitable anchor.  Since Adjustable Scaffolds are designed for masons, they can support substantial loads.  Consult the manufacturer for the capacity of the scaffold you are using.  Access can be provided by a portable ladder, stairs, a manufacturer supplied ladder or direct access.  Consult your manufacturer if you can use the mast of your scaffold for access.

Adjustable Scaffolds are Supported Scaffolds.  TheUSfederal OSHA standards that apply are the General Requirements, 29 CFR 1926.451, including the Supported Scaffold Criteria, 29 CFR 1926.451(c) which addresses scaffold stability and scaffold foundations.  Additionally, The American National Standards, A10.8-2001 has consensus standards that specifically address Adjustable Scaffolds.

Did You Ever Wonder?

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

Did you ever wonder where the OSHA standards came from?  For that matter, did you ever wonder where OSHA came from?  How did the scaffold standards come to be?  Did they always exist?  Have you ever heard of Letters of Interpretation and Directives?  You might be surprised at the answers.

 

The Federal Occupational Safety and Health Administration, OSHA, was created in 1970 when the United States Congress passed a law addressing workplace injuries and deaths.  At the time, multiple rules, standards, and laws enforced by multiple agencies existed but were not consistently enforced.  For that matter they weren’t very consistent or standard either.  What was legal in one state wasn’t necessarily legal in another.  What was seen as a safe work practice in Texas just might not be safe in Illinois.  Statistics illustrated the state of affairs in 1970: Serious injuries and deaths continued to climb.  The 91st Congress took action by passing Public Law 91-596 on December 29, 1970.  This law required, in part, that employers shall:

 

“(1) Furnish to each of his/her employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his/her employees;  (2) Comply with occupational safety and health standards promulgated under this Act.”

 

The law also requires that employees “shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his/her own actions and conduct.”

 

Passing the law was the easy part since safety can sometimes be rather subjective.  What constitutes a safe place of employment?  Your idea of a safe workplace may not agree with another’s opinion.  To bring some consistency to the concept of safe workplace, the law also established an agency within the Department of Labor to develop standards that determined the minimum requirements for a safe workplace, and provide the enforcement to make the standards effective.  Thus was born the Occupational Safety and Health Administration, OSHA.  Also established at the same time was the OSHA Training Institute, OTI, to assist employers in providing training for employees.

 

How do you write regulations that everybody can agree on?  First, you have to be real good at writing standards.  Secondly, you have to make sure that the regulation, or standard, is applicable to the specific hazard and will not be misinterpreted.  As a matter of fact, in a perfect world, no interpretation is required and everybody agrees on the meaning of the standard and the proper application of that specific standard.  Too bad it’s not a perfect world.

 

Luckily, consensus standards and other rules existed prior to the establishment of OSHA.  In other words, there was a foundation on which to build a system of mandatory standards.  The American National Standards Institute, ANSI, had developed many standards prior to OSHA and for that matter, continues to develop consensus standards today.  The ANSI standards are based on earlier standards and guidelines that were developed by insurance companies going back to the turn of the last century (that’s like a hundred years ago!)  Scaffold standards can be traced back to the 1920’s when at least one insurance company issued guidelines for scaffolding and other construction activities.

 

The scaffold standards have evolved since 1971 when OSHA developed their first scaffold standard.  In fact, in 1977 OSHA decided that the first scaffold standard could use some improvement and consequently started reviewing and rewriting the scaffold standard.  This was a long arduous process but finally in 1996 the present standard was issued.  However, as good as the present standard is, clarification is required from time to time, especially when attempting to apply the scaffold standard to s specific situation that doesn’t seem to “fit” any standards.  This is where Letters of Interpretation come into the picture.  Anybody can write to OSHA and ask for a Letter of Interpretation.  Once the request is submitted, OSHA carefully reviews the standard and other available information to determine an interpretation that meets the intent of the standard.  A letter is published and becomes enforceable just like the standard itself.

 

Directives are another tool that OSHA uses in conjunction with the standards.  Directives are different than Letters of Interpretation. The purpose of the Enforcement Directive for Scaffolds, for example, is to give guidance to OSHA compliance officers for enforcing the scaffold standards.  This directive is useful information and, just like the Letters of Interpretation, is available on the OSHA website, www.OSHA.gov.

 

So, is it a wonder that the OSHA scaffold standards are applicable to many scaffolds?  Not really, once you realize that many people with a lot of expertise have been involved in the development of standards over the years and still are today.  The Scaffold Industry Association, SIA, has been intensely involved in the development of many scaffold related standards since the association’s inception.  Mr. Jerry Towse, first president of the SIA, recalls:  “We (the SIA) were concerned when the first OSHA scaffold standards were issued because they inadequately addressed the industry’s concerns about safety.  At that time, it was decided the association should be proactive in standard development.”   This involvement includes the ANSI aerial lift standards, (the A92 series of standards), the ANSI scaffold standards, (A10.8), and the present OSHA standards.  Like the SIA, the Scaffolding, Shoring, and Forming Institute, SSFI, has also been involved with scaffold standards since that association’s creation in 1960.

 

You may think the OSHA standards are deficient but I suggest this:  try writing a standard or two.  You’ll find out how hard it is to be precise yet broad enough to apply universally.  You should be thankful to all the involved people who have selfishly contributed to the process.

s�_ae� (�   For Tubular Welded Frame Scaffolds, for example, these are the differences:

 

 

  1. The general industry standards require the use of a guardrail system and toeboard.  The construction industry standards allow the use of a guardrail system or a personal fall protection system.  Also, other forms of falling object protection, besides toeboards, are allowed;
  2. The general industry standards require that the toprail be installed between 36 and 42 inches.  The construction industry standards require the toprail to be installed between 38 and 45 inches;
  3. The general industry standards require that all frame scaffolds be erected by competent and experienced personnel. The construction industry standards require that scaffolds be erected under the supervision of a competent person qualified in scaffold erection, using experienced and trained employees.
  4. The general industry standards require periodic inspections of scaffold equipment.  The construction industry standards require inspections by a competent person prior to each workshift.

 

This short dissertation illustrates the significant differences between the requirements of the two standards; use it to recognize that you cannot take the general industry standards and apply them to a construction industry application or use the construction industry standards in a general industry application.  It is necessary to identify which standards apply for the specific application.  And of course, no matter which standards apply, it is a safe scaffold that is required.

Help, I’m Falling!

By | Aerial Lifts, Fall Protection, Mast Climber, OSHA Standards & Regulations, Resources, Scaffolding Platforms | No Comments

Fall protection for aerial lift operators and users, while straightforward in my mind, seems to be a mysterious phenomenon that bewilders the minds of many and produces myths worthy of aNew Yorkbest selling novel!  Fortunately, there is no need for it to be this way.  Admittedly, the Federal Occupational Safety and Health Administration, OSHA, standards that apply to aerial lifts can be a bit confusing, to say the least.  However, once explained, it becomes rather clear as to what is expected of aerial lift users.  Besides the standards, a more basic concept can be applied to fall protection for aerial lifts; that concept is, simply put, what’s the best way to keep users from falling?  You can’t get much more basic than that.  Let’s look at this concept first, and then look at the US OSHA standards to see why they are the way they are.

 

The American National Standards Institute, ANSI, has a number of classifications for the group of equipment known as aerial lifts.  In construction, the four most common types include “Boom Supported Elevating Work Platforms,” “Manually Propelled Elevating Aerial Platforms,” “Self-Propelled Elevating Work Platforms,” and “Mast-Climbing Work Platforms.”  On the jobsite, this equipment is also known as boom lifts, scissors lifts, and mast climbers.  The significance of all this is that boom lifts respond very differently to the requests of the operator than either the scissors lift or the mast climber.  The platform of a boom lift is supported by a single column type strut or beam.  This strut can be vertical, horizontal and any angle in between.  Scissors lifts, as the name suggests, have interlocking diagonal struts that allow the platform to raise and lower vertically directly above the base support.  Mast climbers, as the name suggests, has vertical struts/masts that allow the platform to raise and lower vertically by climbing the mast or masts.  The advantage of the boom lift is that the platform can go up and out, and in some cases, up, out, down and under, while the scissors lift platform and mast climber platform primarily only go up and down, similar to an elevator in a building.   These varying characteristics dictate the type of fall protection that is required.

 

The dynamic motion of a boom lift creates the phenomenon not unlike a catapult.  The boom can store sufficient energy during movement that it can literally launch the operator up and out of the basket.  Scissors lifts and mast climbers don’t develop this type of force and consequently is not normally a concern for fall protection.  What all this means is that on scissors lifts and mast climbers we want to keep the worker from walking/falling off the platform while on boom lifts we want the worker not only to be protected from walking off the platform but also from being launched from the platform.  This means the first line of protection on all lifts is the guardrail system.  For boom lifts it is also necessary to restrain the employee so he/she never leaves the platform.  A fall restraint system is required to do this.  Therefore, on boom lifts, not only is there a guardrail system to protect the employee but also an anchor to hook the fall restraint system to.  Please note that it is a restraint system, not a fall arrest system that is used.  We don’t want to have to catch you after you have been launched but rather to keep you from ever launching!

 

How does this approach to fall protection fit with the applicable regulations, you ask?  Well, first and foremost, comply with the manufacturer’s instructions.  These machines are sophisticated devices and the manufacturer is the authority on fall protection for his/her specific device.  The manufacturer may require more protection than I described above.  For example, scissors lifts may require the occupant to utilize personal fall arrest equipment attached to the specified anchor.  The manufacturer may require other safety devices that are not required by the OSHA standards.  If this is the case, you are expected to comply with those requirements provided they are more restrictive than the OSHA standards.  This brings us to the standards.

 

Aerial lifts are addressed in Subpart L of the Construction Industry Standards, specifically section 29 CFR 1926.453.  These standards are exclusive to aerial lifts.  (Note that the Scaffold General Requirements, 29 CFR 1926.451, do not apply to aerial lifts, as clarified in the first sentence of that section.)  Because OSHA standards cannot reference standards that are not in existence at the time of issuance, 29 CFR 1926.453 references ANSI Standard A92.2-1969 which was the applicable standard in 1986 when the revised scaffold standards were first proposed.  This 1969 standard does not reflect the multitude of machines that have been developed since then; unfortunately OSHA is stuck with this limitation.  Fortunately, OSHA recognizes this limitation and allows that equipment manufactured and used in compliance with more current standards will be recognized to be in compliance with 29 CFR 1926.453.  (See Non-Mandatory Appendix C of the OSHA Scaffold Standards for a list of those standards.)  This leads us specifically to Standard 29 CFR 1926.453(b)(2)(v) which requires that “a body belt shall be worn and a lanyard attached to the boom or basket when working from an [extensible or articulating boom platform] aerial lift.”  A note follows this regulation pointing out that a belt cannot be used for fall arrest but can be used for tethering.  Remember from the discussion above, that if you are properly anchored to the basket of a boom lift, you will never leave the basket and consequently will not be exposed to the forces of a fall.  It should be obvious from all this that if you do not anchor yourself properly you will leave the platform or basket and then we will have to catch you.  In that case you better be wearing a harness or you will probably kill yourself.  Bottom line, use short lanyards when using a boom lift so you never leave the basket.

 

Guardrail systems are used to keep workers from walking/falling off the platform or out of the basket.  Personal fall restraint is required to keep you in a boom lift.  Comply with the manufacturer’s recommendations no matter what type of aerial lift you are using; those requirements may be more restrictive than the OSHA minimum standards.  And a couple of final thoughts:  A 6 foot lanyard used with a restraint belt is a killer, a 6 foot lanyard used in a basket will still allow you to get launched; keep that in mind when you idly hook off so you “look good.”  And if you’re the truck driver loading the boom lift on the truck, watch out—you have a better chance than anybody of getting launched.

Should You Be Committed?

By | Resources, Scaffolding | No Comments

If I was to tell you that I was going to be committed, would you consider joining me or would you look at me with some suspicion?  And why would you look at me with some suspicion?  How about if I was to suggest that you should be committed?  Would you take offense to that?  Well, don’t be offended but I think you should be committed.

In January, the Scaffold Industry Association, (SIA) is going to hold its’ annual Committee Week where the members are asked to commit themselves.  If you are a SIA member, you should plan on being committed!  That’s right, volunteer to be committed; as in join a committee.  Volunteer to join a committee and be committed to improving the state of the scaffold industry.  I, and the rest of the membership, expect nothing less.  Why is that?  Without your input, the SIA cannot represent your interests.  Without your input, the SIA cannot properly respond to the regulatory agencies and other industry associations.

The scaffold industry is regulated by both mandatory and consensus standards.  Mandatory standards include the prolific federal, state, and provincial occupational safety and health standards.  Consensus standards include, among others, the American National Standards Institute (ANSI) standards and the SIA Codes of Safe Practices.  You, individually and through the SIA, can provide input to these agencies through various methods.  For example, whenever new regulations are written, you have the opportunity to provide your opinion as to the language of the proposed regulation.  In fact the SIA has historically provided valuable input into OSHA standards that protect your interests as a member.   The SIA has representation on various ANSI committees concerning scaffolding and the SIA is asked to provide input on standards that indirectly apply to the scaffold industry and its members.  State and provincial agencies frequently request association input on regulations and interpretations of regulations.

Association members represent the SIA at ANSI meetings.  I am the SIA representative for the scaffold sub-committee, ANSI A10.8.  I cannot do my job without your input.  While I am fortunate to have contacts across North America, I cannot possibly know the problems and opportunities that exist everywhere and may be unaware of your specific concerns.  This is true of the other ANSI representatives and the council and committee chairmen as well.  They need your concerns and ideas if the regulations and standards that determine how you must conduct your work are indeed beneficial to you and the industry.

Since regulations and standards affect regional and national commerce, it is important the SIA efforts reflect the interests of all its members, including you.  By participating in the committees and councils of the SIA, your contribution will improve the validity of the association’s efforts and continue to confirm the status of the Scaffold Industry Association as the voice of the industry. And there are plenty of committees and councils where you opinion is needed and requested.  While no one individual has all the answers each individual can, in participation with the group, determine the answer.  There can be no group without the individuals and of course no one individual can be the group.

Can’t get away from business or don’t have the funds to attend the Committee Week meetings?  No problem; send us you opinion, send us your suggestions, send us your ideas.  Participate locally.  The work of the SIA continues year around and the request for information continues year around.  Remember, the scaffold industry is not static but rather is dynamic and fluid.  New ideas, concepts, equipment and methods continue to evolve, requiring continued updating and dissemination of information.  That is precisely why you participation is needed, at the local, regional, provincial and national level.  Don’t let anybody tell you differently.

One definition of committee is “a group of persons elected or appointed to perform some service or function.” (Webster’s Dictionary) That group of persons has to include you if your association is to be meaningful.  The service you perform will improve the association, the industry, and ultimately, your livelihood.  If you don’t think so, don’t participate and watch what happens.

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.

No Assembly Required

By | Aerial Lifts, Resources | No Comments

No assembly required?  That’s right.  Unload that aerial lift off the truck, hop on and away you go.  And go you will – just in ways you may not anticipate.  And that is the problem.  Too many users of aerial lifts think they are a no brainer to use.  They assume there isn’t anything to it.  Push a button, pull a stick; how complicated can that be?  Well, that’s not the complicated part.  To quote the American National Standards, ANSI, for Boom Supported Elevating Work Platforms,

 

“The operation of any aerial platform is subject to certain hazards that can be protected against only by the exercise of intelligence, care, and common sense and not by mechanical means.  It is essential to have competent, careful personnel trained in the intended use, safe operation, maintenance and service of this type of equipment.”

 

The bottom line is that, as with many types of equipment, it is training and skill that will minimize hazards, not additional equipment.  The Federal Occupational Safety and Health Administration, OSHA, has a specific section within the scaffold standards to address aerial lifts.  It is 29CFR1926.453.  Unfortunately, this section of Subpart L is somewhat inadequate for today’s aerial lifts.  Due to circumstances that occurred in the development of Subpart L, it was necessary to reference an old (1969) ANSI aerial lift standard, A92.2-1969, for use as part of the OSHA standard.  This standard, written prior to the proliferation of today’s various types of aerial lifts, does not clarify the type of fall protection required for the different types of aerial lifts.  The result of this is confusion pertaining to the safe use and operation of aerial lifts.  More importantly, it confused the fall protection requirements for aerial lift users.  A careful reading of 29CFR1926.453(b)(2)(v) indicates that “a body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.”  No distinction is given between a “boom lift” and a “scissors lift.”

 

Fortunately, OSHA recognized the confusion that existed due to the reference to the 1969 ANSI Standard.  OSHA remedied the situation by including the current editions of applicable aerial lift ANSI standards in the non-mandatory appendices of the OSHA scaffold standards.  This means that the trained user who complies with the applicable ANSI Standards will be in compliance with the OSHA Standards.  Additionally, if the user complies with the manufacturer’s requirements, he/she will also be in compliance with the safety standards.

 

A review of the ANSI Standards for Boom-Supported Elevating Work Platforms (boom lifts) andSelf-Propelled Elevating Work Platforms (scissors lifts) reveals specific fall protection requirements.  First, both boom-lifts and scissors lifts must have guardrail systems.  Second, all occupants of boom-lifts must use fall restraint equipment to keep them in the basket or fall arrest equipment to catch them if they leave the basket.  Third, all occupants must comply with the manufacturer’s requirements for fall restraint/arrest.  (Fall restraint is keeping you from falling out of or being ejected from the basket.  Fall arrest is catching you after you have fallen out of the basket.  Obviously, fall restraint is highly desirable to fall arrest!)

 

This distinction between restraint and arrest leads us to the issue of body belts.  OSHA outlawed, and for good reason, the use of body belts for fall arrest but has still allowed them for fallrestraint.  Therefore, the reference to a body belt in the standards is correct, provided you are only using the belt for restraint only.  Many employers do not make the distinction between belts and harnesses and therefore only allow employees to use full body harnesses.  This is an excellent practice since it eliminates any potential mistakes.  Furthermore, for restraint to work, only a short lanyard, attached to the manufacturer supplied anchor, must be used.  A worker using a six feet long lanyard can still get launched out of the basket.  This would not be good.

 

Scissors lifts, when used correctly, do not have the potential to launch people off the platform.  Therefore, a guardrail system is normally considered adequate.  However, even in this situation, if the manufacturer of the equipment provides an anchor and specifies in their instructions that occupants must use personal fall protection, then compliance is expected.  In other words, not complying with the manufacturer’s recommendations can be construed as being in violation of the OSHA Standards.

 

If you are a user of aerial lifts, you must comply with all of the manufacturer’s instructions and recommendations.  You also must comply with the applicable ANSI Standards.  If you use aerial lifts, you should have these standards.  In fact, there is no excuse not to have the standards because it is easy to obtain them from the Scaffold Industry Association at a very reasonable cost.  As they say, don’t delay, order today; the life you save may be your own!

Questions You Have Asked About OSHA

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

What is a scaffold?

A scaffold is “any temporary elevated platform (supported or suspended) and its supporting structure (including points of anchorage), used for supporting employees or materials or both.” (OSHA 29CFR 1926.250) This includes frame scaffolds for example, and also two planks supported by two barrels or concrete blocks.

 

What is a limited access zone?

A limited access zone is established whenever a masonry wall is being constructed. It is an area that is established on the side of the wall which will be unscaffolded and its purpose is to eliminate the hazard of the wall, while being constructed, and before it is braced, from falling on employees. For more information, see Subpart Q of the OSHA Construction Industry Standards, 29 CFR 1926.

 

What is a qualified person, as it pertains to scaffolding?

A qualified person is one of two types of individuals. The first individual has a degree, certificate, or professional standing. The second individual has extensive knowledge, training, and experience. In either case, the individual must be able to demonstrate an ability to solve or resolve scaffold related problems.

 

What is a competent person, as it relates to scaffolding?

In the words of OSHA: “A competent person must have had specific training in and be knowledgeable about the structural integrity of scaffolds and the degree of maintenance needed to maintain them. The competent person must also be able to evaluate the effects of occurrences such as a dropped load, or a truck backing into a support leg that could damage a scaffold. In addition, the competent person must be knowledgeable about the requirements of this standard. A competent person must have training or knowledge in these areas in order to identify and correct hazards encountered in scaffold work.”

 

What are the five most serious scaffold hazards?

Based on accident statistics, the five hazards are: 1) Falls; 2) Unsafe Access; 3) Struck by Falling Objects; 4) Electrocution; 5) Scaffold Collapse.

 

Is it necessary to train scaffold erectors?

Yes; it is required by law.

 

Is it necessary to train scaffold users?

Yes; it is required by law.

 

Does Federal OSHA require all scaffolds to be designed by a qualified person?

Yes.

 

What is ANSI?

ANSI is the American National Standards Institute. It is an organization whose members include individuals from academia, industry, and government who develop industry consensus standards for products and processes. The scaffold standard is A10.8-1988. The aerial platform standards are in the A92 series. Several SIA members are also members of ANSI committees and subcommittees and the SIA is the secretariat for the Aerial Platform Standards.

 

What is a safety factor in scaffolding?

A safety factor is an adjustment to the load rating of a scaffold component. In the case of scaffolding, the minimum safety factor is 4. For certain components, such as the suspension ropes for suspended scaffolds, the minimum safety factor is 6. For shoring equipment, the safety factor ranges from 2 to 3. Generally, the safety factor is applied to account for unknown factors.

 

Has training always been required by OSHA?

Yes. Training requirements can be found in Subpart C, General Safety & Health Provisions of the Construction Industry Standards. When the scaffolding standards were updated, specific training requirements for scaffold users, erectors, inspectors, maintainers, and others, were included. These specific training requirements do not replace the original training requirements but rather enhance and clarify the training requirements for the scaffold industry.

 

Does OSHA have a web site?

Yes. It is www.osha.gov.

 

How much does the wind affect erected supported scaffolds?

The effect of the wind on scaffolds is varied based on many factors, including the height of the scaffold, the location of the scaffold, the surrounding environment, the shape of the structure, and whether the scaffold is enclosed, to mention a few. The OSHA minimum tie-in requirements are exactly that: a minimum requirement. Doubling up ties when a scaffold is enclosed seldom is adequate. The only reason more scaffolds don’t fall over is because the wind hasn’t blown very hard and/or the safety factor is compromised.

 

If a supported scaffold is enclosed, and the ties are installed according to the OSHA minimum requirements, what is the potential force on each tie?

Depending on conditions and location, it can be near zero, (no wind,) to 9,000 pounds.

 

Is continuous cross bracing required on all frame scaffolds?

No. While it is a good idea to install continuous bracing, and manufacturers recommend it, continuous bracing is not required provided proper bracing is installed. If you don’t know what proper bracing is, install continuous bracing.

 

 

Who determines what is proper bracing?

The qualified person determines what proper bracing is. Typically, the bracing requirements are shown on the design. In some cases, general guidelines, such as those developed by manufacturers, can be developed for a given scaffold.

 

If a cross brace is missing from one bay of a continuous bay scaffold, is this in violation of the OSHA standards?

Not necessarily. The standards require that all supported scaffolds be braced to “prevent swaying and displacement.” This can be accomplished by a combination of cross, diagonal and straight braces, in combination with sufficient tie-ins.

 

Are clamp-on ladders considered “fixed” ladders and consequently must comply with Federal OSHA Subpart X standards?

No. Clamp-on ladders are a scaffold component and consequently are addressed in the scaffold standards, Subpart L. Clamp-on ladders are not fixed ladders.

 

Does OSHA have any guidelines for the compliance officers pertaining to the enforcement of the scaffold standards?

Yes; it’s OSHA Instruction CPL 2-1.23 (Directive) and can be found on the OSHA website.