Army Corps of Engineers Archives | DH Glabe & Associates

Random Numbers

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

As a prime example, take the standards that relate to the height of toprails in a guardrail system.  Here are the numbers: 36; 38; 39; 42; 45; 48.  How about the height above the level below when fall protection is required?  Here are the numbers:  5 feet; 6 feet; 7 and a half feet; 10 feet; 15 feet; 30 feet.  And just for fun, midrails on a guardrail system are to be either “halfway” or “approximately halfway” depending on which standards apply.  (Can you imagine the “halfway” concept: off by 1/64th of an inch and you just violated the standards!)

Dimensions and measurements are not limited to fall protection but these numbers typify the contradiction in the industry.  It is particularly nasty for those who “just want to build scaffolds” as one frustrated scaffold erector told me.  So, how random is it?  Let’s take a look at the height at which fall protection is required.  The OSHA Maritime standards require fall protection at 5 feet while the OSHA construction standards require fall protection at 6 feet except for scaffolds where the height is 10 feet.  The Army Corps of Engineers, in their recently updated standards, determined that fall protection should be required at 6 feet for all situations including scaffolding.  Apparently things are more dangerous in military construction after all.  Or maybe workers on construction scaffolds know how to fall safely.  Actually there may be a legitimate reason why guardrails are not required for scaffolds until 10 feet above the level below.  It’s based on the increased hazard of attempting to work from scaffolds in the typical commercial ceiling height environment while contending with a guardrail system.  Why the Army Corps chose not to agree with that is unknown to me.  But then, as far as I know, the Army Corps didn’t ask anybody in the Scaffold Industry Association for any comments regarding the revamped Army Corps standards.

What’s interesting about all of this is the apparent lack of solid scientific data to support the numbers.  It is often argued that death can occur from any height—and it’s true.  For example, I am aware of a worker who fell backwards off a scaffold platform approximately 4 feet above the ground.  He unfortunately hit his head on a concrete block and died instantly.  But, on the other hand, you hear about workers who fall from 20 or 30 feet without any lasting injuries, much less death.

So where do the numbers come from?  Based on my research, it appears that much of it extends from earlier standards and codes; unfortunately, the real, original basis for these disparate numbers is lost to history.  In other words, we seem to perpetuate the randomness of the numbers.  I don’t particularly have a problem with that.  For example, 42 inches seems to be a good number for a guardrail height.  (Far be it for me to argue what so many people agree is the right height.  Besides, I don’t have any research to argue that 42 inches isn’t a good height. However, I wonder what the National Basketball Association might have to say about it.)

The real mystery here is why there is so much variability in the required heights and distances.  Why does California insist on a 7’-6” height while the rest of the country is at 10 feet?  Why do the Maritime standards insist on a threshold of 5 feet and the Army Corps of Engineers insist on 6 feet?  The erector I mentioned earlier erects scaffolds in California, Arizona, Nevada, Washington, and Hawaii.  One week he may be erecting scaffolding in a shipyard in Washington (Maritime applies) or maybe at an office building in Seattle where Washington OSHA (WISHA) standards apply.  The next week he may be in the middle of California working on a scaffold at a water treatment plant where California OSHA (Cal/OSHA) standards apply.  But if he is on a Native American reservation in the middle of California, the federal standards apply.  Hopefully he doesn’t go next door to the US Army VA hospital because the Army Corps standards apply!  Unfortunately, the following week our confused erector is in Nevada working on a casino in Las Vegas and since Nevada is a “state plan” state, he must know the nuances of Nevada’s standards.  From there our erector goes to Arizona which is also a state plan state with its own peculiarities.  Hopefully our erector doesn’t have to travel to Hawaii anytime soon; it’s a state plan state too with the potential for variations in the applicable standards compared to other jurisdictions.

Surprisingly, it appears that most, if not all, the standards agree on one thing: the strength of the toprail shall be no less than 200 pounds.  If we can agree on that, why can’t we agree on the rest?  Oh, by the way, those numbers I listed at the beginning of this article are all real and correct.  Do you know which standards they came from?

Applicable Standards

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

Imagine this:  I am a scaffold erector and I enjoy my job.  I like erecting scaffolds.  I know how to build scaffolds but I don’t know much about all the rules that I am suppose to follow.  All I know is that all the platforms are suppose to have guardrails and I have heard that scaffolds are suppose to have toeboards—not sure when I’m suppose to install toeboards—just told that I should install them.  Why do I need a toeboard on an Army Corps job inOhiobut not an office building in Ohio?

Why are there so many different rules?   Don’t bother me with the regulations; just tell me what to do.  Why should it make any difference where I’m at or what project I’m on?  For example, take fall protection.  Isn’t falling inCaliforniathe same as falling inMassachusetts?  Please tell why I should have guardrails on a scaffold more than 7-1/2 feet above the level below inCaliforniabut at 10 feet inMassachusetts?  Better yet, why 7-1/2’ feet inCaliforniabut 10 feet on a casino inCalifornia?  And yet, if you are in a shipyard inCalifornia, working on a federal facility (Navy shipyard) you may have to comply with the Maritime Standards, 29 CFR 1915, which requires that fall protection is required on platforms more than 5 feet above the level below.  And then of course, you may be on a jobsite where the general contractor requires fall protection on all platforms more than 6 feet above the level below.

This isn’t easy for the typical scaffold erector.  I suggest that it is legitimate to ask why there should be so many heights for fall protection.  Why can’t the federal government get their act together and establish a common set of standards?  Why do the various agencies of the government insist on maintaining separate standards for the same things?  Is it possible that maritime scaffolds are that much different that construction scaffolds?  How about Army Corp scaffolds?  What would make this agency sufficiently different so the OSHA Construction Standards wouldn’t apply?  Unfortunately, I hope you aren’t looking for an answer here—I don’t have one.

It is my opinion that there are numerous factors involved in maintaining the status quo.  Unfortunately there isn’t much of a desire to make scaffold erection any easier for erectors, not to mention making it any easier for those charged with the task of enforcing the standards.  Is it realistic to expect a scaffolder to know all these standards and when they apply?  Even if you are the Competent Person, you have to admit that keeping track of all the variations of the same standard can be overwhelming.  Besides, I find it hard to believe that construction workers inMassachusettscan safely fall from higher distances than shipyard workers inMassachusetts.  The hazard is the same; why should the solution be different?  Unfortunately the remedy appears to be non-existent.  Well, maybe nobody really cares whether the standards are simplified or at least combined where it makes sense.  Perhaps it isn’t necessary because erectors don’t voice their opinions.  Maybe it’s not important because erectors and users aren’t complying with the standards no matter what they are.

As I said earlier, I don’t have an answer for coordinating the conflicting standards.  I also don’t know if there is a desire in the industry to do this.  I do know that it is illogical to maintain dissimilar standards addressing the same hazard.  What do you think?