While the construction and engineering industry does come with a certain amount of inherent risk, contractors can be proactive about safety on projects. OSHA sets strict guidelines regarding fall protection measures because falls are commonly responsible for serious workplace-related injuries and deaths. The National Safety Council finds that falls from height are the reason for the most non-fatal days of missed work. Keeping this in mind, contractors and engineers should ensure that all employees receive regular preventative training. Additionally, when working from any height, workers should be provided with the appropriate fall protection system.
In the construction industry, falls are the leading cause of workplace fatalities according to OSHA. In 2015 alone, 350 workers lost their lives due to completely preventable accidents. The National Safety Council found falls are responsible for the most non-fatal missed days of work. Clearly, falls and related accidents can be a large liability for any commercial project. However, with proper fall prevention techniques, contractors can protect their employees and profit margins all at once.
Construction Engineering – The Basics
Construction engineers are key players in promoting the successful implementation of any project worth its time and expense. They work with contractors to identify project challenges, provide value engineering, and ensure safety. Their primary focus is to provide effective solutions without sacrificing the functionality of the final product. Essentially, construction engineers deliver labor, equipment, and materials savings to contractors by employing efficient construction methods to optimize constructability without sacrificing safety.
A lot has been said about falls and fall protection. The U.S. Federal Occupational Safety & Health Administration, OSHA, has emphasized fall hazard awareness and increased enforcement of the fall protection regulations for years in the hope that deaths and major injuries due to falls in the workplace can be reduced. Manufacturers and suppliers are complementing the OSHA emphasis by offering a plethora of products that can be used to keep employees from falling. Or, more accurately, to keep employees from falling from heights to levels below in such a manner that they get injured or killed.
An inside look at why fall protection anchors must be tested
Fall protection! When you put on your harness, tie off to a fall protection system, and step to the edge of the roof on a 20 foot tall building, do you know that you are truly safe? Or is this maybe just a false sense of security that you have been lulled into? Would you feel different if this were a 200 foot tall building?
As we all know, the components of a complete fall protection system are the user’s personal fall protection equipment and a suitable anchor or lifeline to connect it to. If the system is properly designed, constructed and used, it will ensure that you will walk off the jobsite at the end of the day safe and sound. As a user, you can only control the “use” aspect of the system so a great deal of responsibility is on you to ensure your own safety. If you are a gambler, you can take your safety on faith. However, those who do not want to rely on dumb luck need to know their fall protection system.
First, the simple stuff: your body harness and lanyard. They should be purchased from a reputable source with readily available design and testing data from the manufacturer. Utilizing your Fall Protection User Training, you should be able to perform a visual inspection of the equipment to check for damage or excessive wear. If all looks good, you should feel comfortable that your personal fall protection equipment will do its job.
On the other hand we have the anchor portion of the system – this is not so easy. You can look for visible signs of damage or corrosion, but the truth of the matter is that in most cases you have no idea what is behind or underneath the anchor itself. It is in these areas where corrosion hides and maintenance tends to neglect. The truth of the matter is that if the anchor was not designed and installed properly, no amount of maintenance can make it safe to use! You may be thinking the anchor is fine and dandy because that steel beam over there is “big”, or that wall looks “solid” . . . there is no way that it won’t hold 5,000 pounds! This may be true, but as you stand there looking at the “big” steel beam ask yourself this: what is holding the beam in place? Okay there is a steel column at both ends, but what are they attached to? If you don’t know, how can you really be sure that “big” steel beam isn’t going to follow you over the edge of the roof if you fall?
OSHA requires that all permanent fall protection anchors must be tested upon installation and be visually observed annually if they are to remain active. The fact of the matter is that many property owners simply do not know about these requirements as many building anchors are used daily which have never been tested or inspected. This puts you at risk of injury, and the property owner and your employer at risk of a hefty lawsuit if something were to go wrong.
We were recently involved in a project which involved the load testing of existing fall protection anchors around the perimeter of the mechanical penthouse. The anchors were installed on the outside face of the brick veneer and consisted of a steel eye welded to the center of an 18”x6”x 1/8” thick steel plate. The plate was bolted to the wall with two ½” diameter threaded rods and nuts at both ends. On this particular structure, we could observe that the other end of the connection inside of the penthouse was identical to the connection on the outside.
From the pictures above, you may be thinking it looks like someone clearly put some thought and effort into installing these anchors so they must have been designed and installed properly. No rust is apparent and the wall appears “solid” . . . why do they need to be tested??? The reason we were asked to test the anchors is because someone didn’t feel like gambling as they prepared to hang off the side of the building and asked the correct question “can I get a copy of the latest testing and inspection reports?” As it turns out there was no record that the anchors had ever been tested or inspected, and more disturbing that they may have never been designed either. Fortunately in this case, the property owner and contractor were well aware of the OSHA requirements and requested the anchors be tested before use.
Armed only with a single architectural section of the penthouse wall, we felt it would be prudent to perform a structural investigation prior to performing any testing. During this investigation we discovered that the two threaded rods were installed adjacent to the light gauge steel studs at most locations. Running a computer modeled analysis of this configuration yielded results which confirmed that not only were the anchors not suitable for their intended use, but that testing them could potentially damage the building!
Since the existing anchors were determined to be inadequate, new anchors were designed and installed and the old anchors removed and/or taken out of service. During the testing of the new anchors, we were asked to test one of the existing anchors in a location that a new anchor could not be installed due to equipment conflicts inside the building. The test was halted at only 1400 pounds as the outside plate had already deflected ½ inch with this minimal load applied to it!
The topic of fall protection anchors is cussed and discussed all the time, but we still have individuals who are either uninformed regarding the OSHA standards or they simply don’t care. The anchor may look “big”, and that wall may appear “solid”, but the only way to know with certainty that it is safe is through proper testing and annual observation. As a user, you need to be cognizant of your own safety and simply ask for the latest fall protection anchor testing or inspection report before you go trusting your life to it. This will provide you with peace of mind, and you may educate someone else about the OSHA standards in the process which may save another life down the road.
A quiz that evaluates your understanding of the correct installation and use of supported scaffold platforms and fall protection.
How well do you know the mandatory standards that dictate how we are to build scaffolds? Specifically, how well do you know the mandatory standards that counsel us in the proper design and construction of scaffold platforms and fall protection? Let’s find out!
Here is a quiz to see if you know your stuff. The answers can be found below. The first set of questions is “true or false” while the second set is “fill in the blank.” No cheating on this; try it first from memory and if you don’t get a perfect score see if you can find the correct answer in the federal OSHA standards. And don’t look at the answers until you are done!
- All scaffolds need at least one platform to be a scaffold.
- The minimum width platform for a suspended scaffold is 24 inches.
- The maximum width platform for a two point suspended scaffold is 48 inches.
- A boom lift does not need a guardrail system.
- You can guess at the required strength of a fall protection anchor as long as it looks like it can hold 5,000 pounds.
- Plank used for a platform can be of any material and strength as long as it can hold four times the intended load.
- Aluminum plank cannot be used with steel scaffolding because of galvanic action.
- The minimum distance a solid sawn wood plank must overhang its support is 12 inches unless it is secured from movement.
- The height of a toprail above a scaffold platform is 42 inches, plus or minus 3 inches.
- You must wear personal fall protection equipment and have a guardrail system when working on a multi-point suspended scaffold.
- If you are wearing personal fall protection while on a tubular welded frame scaffold platform, you don’t need a guardrail if the platform is no more than 7 feet above the level below.
- Same question, different platform height: If you are wearing personal fall protection while on a tubular welded frame scaffold, you don’t need a guardrail if the platform is no more than 12 feet above the level below.
- Toeboards are part of the guardrail system.
- If you know you are not going to fall, you don’t need fall protection while on a scaffold.
- You have to wear personal fall protection and have a guardrail on a mobile scaffold if you are going to ride it.
Answers to the True and False Questions: 1, True; 2, False; 3, False; 4, False; 5, False; 6, True; 7, False; 8, False; 9, False; 10, False; 11, Trick question—you don’t need fall protection because the platform is less than ten feet above the lower level — True; 12, True; 13, False; 14, Don’t you wish-False; 15, False, but then if you are riding it you like to tempt fate.
Fill inthe blank
- The maximum gap between platform units is ___________________ inches.
- The minimum toprail strength is ______________________ pounds.
- The height at which fall protection is required on scaffolds is _____________ feet.
- The minimum overlap for plank is _____________ inches unless the plank is secured from movement.
- The minimum width platform on a supported scaffold is _____________inches.
- Fall protection for scaffold erectors is determined by the _____________________ competent person.
- For a platform on a supported scaffold, the platform shall extend from the front _________________ to the _________________ supports.
- Designed personal fall protection anchors must have a safety factor of _____ to one.
- Scaffold Platforms shall be designed by a _________________ person.
- The maximum space between the edge of the platform to the guardrail system is _________________ inches.
- For normal use, if the front edge of the platform is no more than __________ inches from the work surface, it is not considered an open sided edge and does not need fall protection.
- The stamp on the side of a scaffold grade plank shall read: ________________________.
- If an 8’0’ long plank is not secured, the maximum cantilever past its support is _________inches.
- The maximum distance between guardrail posts on a scaffold is ___________ feet.
- When you hook off the lanyard of your personal fall protection system to the toprail of a scaffold guardrail system, the rail has to be able to support __________pounds.
Answers to Fill in the Blank questions: 16, one; 17, two hundred; 18, ten; 19, twelve; 20, eighteen; 21, employer’s; 22, uprights, guardrail; 23, two; 24, qualified; 25, nine and one half; 26, fourteen; 27, it shouldn’t read anything– there is no requirement; 28, twelve; 29, trick question—there is no maximum as long as the rails can support 200 pounds; 30, 200—your personal fall protection isn’t being used since you are behind the guardrail, you are just “storing” your hook!
Masons are allowed to be exposed to fall hazards due to over-hand bricklaying while on steel supported scaffolds; the use of side brackets (knee-outs) with supported scaffolds.
It is difficult to imagine masonry construction without scaffolding. Prior to the advent of steel frame scaffolding, Bricklayer’s Square scaffolding was used to provide an elevated work platform for the masons to conduct their work. Starting in the 1930’s, steel scaffold frames slowly replaced the wood scaffolds commonly used by masons. Adjustable scaffolds, specifically designed for masons, became available in the 1970’s and the evolution continues today with mast climbers and other powered platforms being used by masons.
In spite of the variety of the equipment used by masons, several issues have persisted regarding the proper use and safety of scaffolds. The first issue involves the fall exposure that masons have while constructing a brick wall. The federal Occupational Safety & Health Administration, OSHA, standards recognize this issue and in 29 CFR 1926.451(g)(1)(vi) specify that “Each employee performing overhand bricklaying operations from a supported scaffold shall be protected from falling from all open sides and ends of the scaffold (except at the side next to the wall being laid) by the use of a personal fall arrest system or guardrail system.” While clear in its intent, there are still people who do not understand this. Simply stated, we allow the mason to be exposed to a fall hazard. That’s right, the mason can fall over the wall if he so chooses. However, any reasonable mason understands that if he leans over too far, he will fall over the wall! Typically, masons like to lay brick at waist high which means that the wall acts as the guardrail—problem solved. In those instances where the wall is lower, then yes, there is a fall hazard. But the hazard of trying to work through a guardrail system laying brick frankly is a greater hazard. Please note that only those who are “performing brick laying operations” are allowed to be exposed to the hazard. In other words, if you aren’t laying brick, you can’t be there.
The second issue involves the use of side and end brackets (commonly, and incorrectly, called outriggers). The normal use of these brackets is on the front of the scaffold, between the wall being constructed and the scaffold front leg. These brackets support the plank for the masons and are moved up in convenient increments as the wall increases in height. There’s nothing wrong with this installation. The problem is when masons install these brackets on the back of the scaffold and then used them as a landing or storage platform for brick and mortar. This is not good unless these brackets have been designed for that purpose. In fact, OSHA addresses this issue in 29 CFR 1926.452(c)(5)(iii) by emphatically stating that these brackets shall be used to support personnel “unless the scaffold has been designed for other loads by a qualified engineer.” The reason for this is that it is easy to overload the brackets and also easy to tip the scaffold over, nether prospect being very appealing to the mason. Keep in mind that the standard doesn’t say you cannot do it; if you would like to do it, hire an engineer who can help you.
The third issue that appears on occasion has to do with the material on the scaffold platforms. There is another OSHA standard, 29 CFR 1926.250(b)(5), that “Materials shall not be stored on scaffolds or runways in excess of supplies needed for immediate operations.” A quick read of this standard would suggest that a mason could have no more than a few brick or block on the scaffold at any given time. In fact, OSHA even issued a Letter of Interpretation that stated that all materials had to be removed from the scaffold at the end of the day. Fortunately, OSHA clarified this letter and stated that the hazards being addressed by this standard included falling objects and scaffold overload. OSHA concluded that since these potential hazards are specifically addressed in the scaffold standards, while leaving materials stored on a scaffold may be a violation of 29 CFR 1926.250(b)(5) it shall be considered a de minimis violation, one that carries no fines. Of course it is assumed that the mason will make sure the brick and block will not fall off the scaffold and the scaffold is not overloaded. This particular issue has appeared recently on jobsites where the Army Corps of Engineers regulations, EM 385, are enforced. As with all standards, it is important to know what the intent of a particular standard is and what hazard is being addressed. Once this is understood, it is much easier to resolve any issues regarding the storage of materials.
As long as we have brick and block walls, we’ll have scaffolding. Scaffolding has proven to be effective and safe, provided you know how to use it safely. Do you?
A stimulating and thought provoking discussion addressing safety concerns with scaffolding.
2012 will be an interesting year with the economy, presidential elections, wars, and unemployment weighing heavy on our minds. In an effort to keep your mind off these depressing subjects, I thought it would be a good idea to focus on what you enjoy—scaffolding! Well, it beats thinking about the economy tanking and besides, this is a magazine for scaffolding and access.
Have you ever wondered what would happen if everybody was perfect? Scaffolds would be perfectly constructed and perfectly used by perfectly trained employees. Now there’s something to think about. Just think of the ramifications. No angry jobsite safety monitors; no OSHA citations; no injuries; no deaths. I wonder what that would do to the unemployment figures.
Why do people like to misuse and abuse scaffold components? Take knee-outs and brackets as an example. Why do erectors think knee-outs will support ten tiers of scaffold on top of them and why do users think brackets will hold a mountain of block and brick?
What would happen if we had no OSHA standards? Would injuries and deaths increase, stay the same, or decrease? What would the industry do? What would you do? Would you do anything differently? What if there were no compliance officers? Would it make any difference to your behavior? Why do we not have one set of standards for the scaffold and access industry in this country? For example, are the states so unusual that we have to have different standards in California and Michigan? Why did Washington State rewrite the federal OSHA standards in a “friendly” prose? Apparently nobody in Washington understood that the standards are not instructions but rather are minimum, enforceable requirements.
Why did the Army Corp of Engineers write a separate scaffold standard somewhat modeled after the federal regulations but yet sufficiently modified so that it is extra confusing? It would almost seem that scaffolding and physics mutate into strange creatures from state to state and agency to agency. This could get scary!
Why do we equate longevity with expertise? You know, just because you have been doing something over and over doesn’t make it right. And the opposite is true; how can a person fresh out of school be a consultant? And then we have someone on TV who said: “I’m not stupid you know, I just don’t know stuff.” Is there a way in 2012 to get scaffold users to know more stuff and increase their expertise?
Why do general safety consultants who have never erected a scaffold think they know more about an erection than a scaffold erector? Why do some scaffold erectors think they are exempt from the accepted safety practices? Why is everybody an expert in fall protection and scaffolding? How can a compliance officer, fresh out of school, understand the 28 subparts of the OSHA Construction Standards? Why do compliance officers get minimal training in scaffolding?
Why is the American Society of Safety Engineers the secretariat of the ANSI scaffolding standard and not the SIAI? And here’s something to really ponder: Has anyone measured the cost/benefit ratio regarding the extensive and some may argue oppressive, government intervention in the scaffold industry?
What will 2012 bring for you? I wish for you a prosperous, enjoyable year and you experience a year of good health free of injury.
A practical explanation as to the relationship between the OSHA standards, enforcement, compliance and safety in the construction industry.
It’s been a long time since I first became involved in the business of scaffolding. My experience has included a lot of scaffolds, a lot of places and a lot of people. It has also included a lot of regulations. As a blossoming young engineer, I still recall asking by boss how OSHA fit into the design of scaffolding. Since federal OSHA was just a couple of years old at that time, he responded with a clearly stated: “I don’t know.” Forty years later, it appears that we still don’t know how OSHA fits into the design, construction and use of scaffolding. To be fair to federal OSHA, it doesn’t appear that any regulations, standards, codes or guidelines fit into the design of scaffolding. Now, before you get yourself all wound up, this may be somewhat of an extremely broad statement. But think about this: We have standards regarding fall protection and more specifically guardrail systems. In my research I have found guidelines regarding guardrails going back to the 1920’s, almost a century ago. And we still have people designing, constructing and using scaffolds without fall protection. If nothing else, we have consistency.
So what’s the problem? Is it poor enforcement? Is it poor training? Is it poor knowledge? Is it ignorance? Or maybe we just don’t care. Being a Professional Engineer, and accepting the responsibilities that go with the privilege, I am obligated to comply with the myriad of regulations, standards and codes that apply to the profession. Not to do so will result in the loss of my license and opportunity to earn a living. I don’t state this because I think I am special, but rather qualified professionals (degreed and licensed or not) accept the obligation that is or should be expected in the business. I don’t agree with all the regulations; for that matter I’m not really keen on any of the regulations—it certainly stifles constructive creativity. In fact, regulations are insidiously invading all aspects of our lives, resulting not only in a dumbing down of the industry but also in an erosion of expertise, efficiency, economy, and productivity.
Of course, those tasked with the enforcement of these regulations smugly point to the results of their policing actions. They publish yearly results of their efforts as if those efforts have any real effect on the industry. Frankly, the annual OSHA list of the top 10 violations has no relation to the degree of danger involved in the infraction. For example, scaffolds always show up in the top ten, suggesting that there is a real problem with safety in the industry. But is there a problem? Perhaps scaffolding shows up so frequently because infractions are easy to spot and the compliance officers haven’t been trained to evaluate where the real hazards are.
One of the favorite activities these days is the harassment of professional scaffold erectors (casual erectors, where the problems really occur, seem to be immune.) Statistics indicate that the death rate of professional erectors is extremely low, particularly when compared to the 80 annual deaths that occur with scaffold usage, the deaths in construction and more dramatically when compared with the approximately 37,000 people killed on the highways each year.
The situation is becoming so ridiculous due to what I think is a growing hysteria about safety and the lack of understanding of the actual hazards. Enormous amounts of time and energy are uselessly spent deciding whether a regulation has been violated instead of investing in the safe productive work that should be happening. How many times have you sat in a meeting ascertaining whether there is compliance with the regulations? How many hours have been wasted bickering about the nuance of a regulation instead of determining how to get the work done safely?
I am not advocating the abolishment of enforcement but something has to change. It is absolutely amazing how people think they are experts in erector fall protection, for example, and yet have never erected a scaffold in their lives. And yet we give them the authority and take it away from the people most affected. Furthermore, it is stunning to me how many government agencies, construction industry organizations, unions and engineering committees feel compelled to propagate more and more regulations, many applying to scaffolding, and yet do not even bother contacting the Scaffold and Access Industry Association or the Scaffold Shoring and Forming Institute for input. Are you aware that the American Society of Civil Engineers has a code regarding construction loads which includes specifications for scaffold loading? I didn’t think so.
I can sure complain about the problem but unfortunately I don’t have a snappy quick solution. We cannot abolish decent standards and codes nor can we abolish enforcement—those are needed for those employers and employees who just don’t get it. But we do need to abolish the politics in safety. Have you ever wondered why we chase after the employer but not the employee? Me too. Have you ever wondered why compliance officers don’t receive sufficient training for the task at hand? Me too. Have you ever wondered why so many designers and constructors erect scaffolds without having any clue as to what a safe scaffold is? Me too. Have you ever wondered why we allow the sale of scaffolding in this country without any idea of its load capacity? Me too. Have you ever wondered why safety consultants have such a poor understanding of the true hazards in scaffolding? Me too.
Forty years ago we were killing and maiming scaffold users. We’re stilling doing it today. And I still don’t know how OSHA fits into the safe design of scaffolding. However, I do know what a safe scaffold is. Do you?
An assessment of the OSHA standards that apply to fall protection for scaffolds and scaffold users and erectors.
Have you ever asked yourself how many ways fall protection can be screwed up, particularly on scaffolds? Well, based on my experience, misapplication and misuse is only limited by the number of workers on the job. Rationale doesn’t seem to be a consideration nor does common sense. I recently testified as an expert in a lawsuit where the employer insisted that the reason the employer did not want the employees utilizing personal fall arrest equipment is because if the suspended scaffold fell it would entangle the employees in the rigging. Lucky for the employer the employees listened. Unlucky for the employees, they rode the scaffold down and died in the process.
So why is it so difficult to provide fall protection? Is there magic? Nope-no magic; you just have to know and understand how this stuff works. Let’s review a few things and see if we can sort it out.
Fall protection regulations/standards can be found in a number of references. In construction, the federal OSHA standards address scaffold fall protection in Subpart L and M. Well, actually it is addressed in Subpart L, not M. However, if you are going to use personal fall arrest equipment, then you have to use the applicable standards that are found in Subpart M, namely 29 CFR 1926.502(d). This is where all the good regulations regarding lanyards, connectors, dee-rings, snaphooks, horizontal lifelines, anchor strength, freefall distance, deceleration distance, maximum arresting force and related topics are hiding. In fact part of the feasibility test for scaffold erector fall protection is located in 29 CFR 1926.502(d). Of course, this is where plenty of the confusion starts since it appears the 502(d) standards are either misunderstood, misread, or maybe just not read. Here are a few of the myths and misconceptions that occur regarding the use of personal fall arrest systems (PFAS):
- Using (not wearing but actually using) PFAS won’t hurt you;
- Many people actually use PFAS;
- Tying off is the same as fall arrest;
- 100% tie-off works;
- Scaffold erectors are exempt from fall protection;
- Scaffold erectors aren’t exempt from fall protection;
- Restraint is the same as fall arrest;
- Positioning is the same as fall arrest;
- PFAS anchors must hold 5,000 pounds;
- Guessing an anchor can hold 5,000 pounds is acceptable;
- Nobody knows how much force is exerted on the anchor when an employee falls;
- The potential loads on horizontal lifeline anchors aren’t very high;
- The 5,000 pound anchor strength is based on science;
- You don’t have to be a competent person to determine if another is competent;
- The Goodyear blimp doesn’t make a good anchor;
- Money (financial burden) cannot be included in feasibility;
- There is an OSHA definition for “feasibility”;
- An anchor that looks good works;
- A scaffold erector can tie off at her feet, especially if it looks good;
- Supported scaffolds make good anchors;
- Supported scaffolds don’t make good anchors;
- You can tie off to scaffolds;
- You cannot tie off to scaffolds;
- All OSHA compliance officers can correctly evaluate PFAS;
- All scaffold erectors can correctly evaluate PFAS;
- All employers can correctly evaluate PFAS;
- 100% tie-off is the same as 100% fall protection.
If you think any of these myths are true, you aren’t the competent person you think you are. Well, except for the Goodyear blimp thing; that may be true! The point here is that too many people have the apparent authority to promulgate inaccuracies. Personal fall arrest is quite simple in theory, difficult in practice. The freefall distance is a critical component that directly impacts the required strength of the anchor. Likewise, the deceleration distance has a direct impact on the anchor load. More freefall and less deceleration distance dramatically increases the anchor load. (Think jumping into a pool full of marshmallows as opposed to landing on a concrete sidewalk.) Is insisting that the leading edge scaffold erector tie off at his feet really any better than allowing him to use his skill and experience to minimize the fall hazard through the use of safe erection techniques?
Finally, the fall protection standards work for stationary employees; that is an employee working in one location, rather than walking back and forth over a distance as scaffold erectors tend to do. A vertical lifeline is not conducive to straying horizontally from the anchor and horizontal lifelines only work if there is no scaffold above you. Besides, the anchor in a horizontal line can easily see load in excess of 10,000 pounds if not rigged properly; it’s tough to get a scaffold to hold that.
What is a person to do? Well, for supported scaffold erectors complying with 29 CFR 1926.451(g)(2) would be a good place to start. This standard requires that the employer have a competent person “determine the feasibility and safety of providing fall protection for employees erecting or dismantling supported scaffolds.” Of course, this standard doesn’t say that you have the right to tell the competent person that he/she is wrong. This standard doesn’t say you get to question the decision. But if you are competent, this standard sure gives you the right to determine if he or she is indeed competent! In other words, be sure you’re sure before you see if they’re sure. Think about it.