suspended scaffold Archives | DH Glabe & Associates

Pop Quiz: 30 Questions About Scaffolding

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


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

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Suspended Scaffold Q & A

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A suspended scaffold is a marvelous tool for workers to utilize to gain access to work locations that would be difficult if not impossible to otherwise reach. Unfortunately, the general perception is that suspended scaffolds, particularly two point suspended scaffolds such as window washers two point suspended scaffolds, are inherently dangerous and those individuals who use them are similarly inherently dangerous. This is due in no small part to the media exposure that suspended scaffold failures receive. The reality indicates otherwise. Perhaps these questions and answers will help mitigate the fear of suspended scaffolds.

What is a suspended scaffold? A suspended scaffold is a temporary platform that is supported by non-rigid means such as cables, chains or ropes. It is not to be confused with supported scaffolds which are temporary platforms that are supported by rigid means such as legs, posts or frames.

Is a suspended scaffold the same as a hanging scaffold? No. A hanging scaffold is a “temporary work platform without support from below, secured to an overhead structure using fixed length rigid suspension members” while a suspended scaffold utilizes non-rigid suspension members.

In addition to a guardrail system, are users of all suspended scaffolds required to wear personal fall protection equipment? No. A user of a single point or two point suspended scaffold, that is a platform suspended from either one rope or two ropes, must wear personal fall protection equipment properly connected to a lifeline. The reason for this requirement when using a single point suspended scaffold is obvious: if the rope breaks, you are in big trouble if you aren’t wearing a harness connected to a lifeline and anchor. On a two point suspended scaffold, typically only one line breaks, leaving the platform hanging vertically (and making really cool photos for the media) with one worker dangling from his lifeline while the other worker is desperately clinging to the other suspension rope.

Are you telling me that workers utilizing a temporary platform that is supported by four suspension wire ropes don’t have to wear harnesses secured to an adequate anchor?According to most regulations, yes.

That doesn’t sound right—are you messing with me? Nope.

Why doesn’t a multi-point suspended scaffold user have to wear a harness attached to an adequate anchoring system? It is assumed that the platform is sufficiently rigid so that if one suspension rope fails, the platform will remain more or less level and the workers will not slide/fall off the platform. Of course, if your platform lacks the necessary rigidity, you should be utilizing personal fall protection. For example, if you are suspended by three ropes, you probably need to utilize personal fall protection for the unlikely event that you will lose one of your suspenders. On the other hand, if you are on a rigid platform suspended by many suspension lines, such as a suspended platform under a bridge, personal fall protection is probably not warranted. Of course, you must always comply with the qualified scaffold designer’s instructions.

Why do single and two point suspension scaffolds seem to frequently fail? They don’t. If you look at how many suspended scaffolds are used daily in North America, you will find that the failures are insignificant. It’s just that the media likes to report them, You Tube likes to show them and people like to talk about them! (Of course, if you are the worker who experiences a failure, it probably won’t seem insignificant to you.)

Does a cantilever beam used to support the rope that supports an elevated suspended temporary platform have to be designed by a Professional Engineer? Maybe and maybe not.

When is a Professional Engineer required? First of all, the Professional Engineer has to be qualified. That qualified Professional Engineer is required for all multi-point masons suspended scaffolds where the cantilever beams used to support the ropes are secured to the floor. Usually a qualified Professional Engineer is required to design the cantilever beam and rigging, particularly if it is purpose designed for a specific situation. Also keep in mind that many agencies, such as Departments of Transportation, require a qualified Professional Engineer be involved.

Are suspended scaffold erectors required to utilize (wear) personal fall protection equipment? Erectors are expected to utilize personal fall protection equipment when they are exposed to a fall hazard, such as when they are installing rigging on a roof or open sided floor.

Do suspended scaffold users have to have a license/permit to operate a suspended scaffold? Perhaps; it depends on the jurisdiction. Large cities, some counties and state governments require licensing and/or permitting. Before starting any scaffold project, it would be wise to determine the necessary regulatory requirements.

Is a temporary suspended scaffold the same as a permanent suspended scaffold? No. Temporary suspended scaffolds must comply with a different set of regulations and standards than a permanent installation, known as a “PI.” As the names suggest, a temporary suspended scaffold is commonly used in the construction of new structures and intermittent maintenance while a PI is specifically designed for a building, installed permanently on that building, and is intended to be used for providing routine maintenance and renovation.

What appears to be the most common cause of suspended scaffold failures and why? The most apparent cause is lack of training. There are so many safety devices incorporated into temporary suspended scaffold equipment, such as overspeed brakes and extremely high safety factors that it requires ignorance and possibly purposeful stupidity to make them fail.

What is the most important aspect of suspended scaffold utilization?  Training.

Where can I get that training? One good source is the Scaffold & Access Industry Association.

Do You Know Suspended Scaffolds?

By | Cantilever Beam, Hoists, Scaffolding | No Comments

Are you familiar with suspended scaffolds?  Do you know the difference between a suspended scaffold and a hanging scaffold?  Well, here’s a chance to show your friends and neighbors how well you know suspended scaffolds.  Take this quiz and see if you are the best of the best.

The answers are at the bottom of the page—no cheating!

 True or False

  1. ____A suspended scaffold is the same as a hanging scaffold.
  2. ____Outrigger scaffolds are one type of suspended scaffolds.
  3. ____You don’t need to utilize personal fall protection on a Multi-point Suspended Scaffold.
  4. ____Suspended scaffold users do not need any training if they are not operating the hoists on a suspended scaffold.
  5. ____Access is not required for a suspended scaffold.
  6. ____Counterweights for a cantilever beam can be ice or Jell-O.
  7. ____The safety factor for wire suspension ropes is at least 8.
  8. ____Counterweights cannot be used to stabilize outrigger beams on Mason Multi-point suspended scaffolds.
  9. ____Guardrails are not required on two point suspended scaffolds if all the occupants are wearing personal fall arrest   equipment.
  10. ___Guardrails or equivalent are required on Boatswains’ chair scaffolds.
  11. ___Outrigger beams secured directly to the roof do not require tiebacks.
  12. ___Suspended scaffolds shall be designed by a competent person and installed under the supervision of a qualified person, competent in scaffold erection.
  13. ___Vertical pickup means a rope used to support the horizontal rope in catenary scaffolds.
  14. ___Tiebacks only need to be one half the strength of the suspension ropes since they are there for back-up, not suspension.
  15. ___Sand can be used as a counterweight provided it is in a sealed strong metal container.


Now for the tough part, fill in the blank!

  1. When wire rope clips are used on suspension scaffolds, there shall be a minimum of ________ installed per connection.
  2. A stage rated for two workers or 500 pounds can support ________workers.
  3. Ropes shall be inspected for defects by a competent person prior to each ___________.
  4. Manually operated hoists shall require a _________crank force to descend.
  5. Wire rope clips shall be installed according to the __________recommendations.
  6. A two-point suspended scaffold is supported by _________ suspension ropes.
  7. Two-point suspended scaffold platforms shall not be more than ______inches wide unless it is designed by a ________person to prevent _________conditions.
  8. Suspension scaffold means one or more platforms suspended by _____ or other _______means from an overhead structure.
  9. The toprail of a suspended scaffold guardrail system must be able to withstand a force of at least ________pounds.


True or False Answers:

  1. False.  A hanging scaffold is constructed with rigid tubes while a suspended scaffold hangs from ropes.
  2. False.  Outrigger Scaffolds are a type of supported scaffold.
  3. True.  You need to install a guardrail system.
  4. False.  All scaffold users need training.
  5. False.  Proper access is required for all scaffolds.
  6. False.  The ice may melt and you might eat the Jell-O.
  7. False.  The minimum safety factor is 6.
  8. True.  The beams must be anchored to the supporting structure.
  9. False.  A guardrail system and PFE is required.
  10. False.  How do you attach a guardrail to a chair?
  11. True.
  12. False.  Suspended scaffolds shall be designed by a qualified person and installed under the supervision of a competent person, qualified in scaffold erection.
  13. True.
  14. False.  Tiebacks must be equal in strength to the suspension rope.
  15. True.  While not recommended, as long as the sand cannot leak out, it’s okay.
Fill in the Blank Answers:
  1. 3
  2. Depends on the weight of the workers.  You can put 5 on if they only weigh 125 pounds each.  Alternatively, if Bubba weighs 400 pounds, only he can be on it.
  3. Workshift.
  4. Positive.
  5. Manufacturer’s
  6. 2
  7. 36, qualified, unstable
  8. Ropes, non-rigid
  9. 100

What is the Foundation for the Foundation?

By | Aerial Lifts, Cantilever Beam, Resources, Scaffolding | No Comments

Identification of the correct safety factors for scaffold foundations.

Foundations are a necessary part of any scaffold, whether it is a supported scaffold, a suspended scaffold, or an aerial lift.  Webster’s dictionary describes a foundation as “the natural or prepared ground or base on which some structure rests.”  Webster goes on to describe a base as “a bottom support; that on which a thing stands or rests.” Without a foundation, or base, the scaffold is useless.  Think about it: if a supported scaffold, that is a temporary elevated platform that is supported by rigid legs or posts, doesn’t have a solid foundation, it will collapse.  The same is true for aerial lifts such as scissors lifts or boom lifts, where it is very important that the foundation is strong enough to support the machine.

What about suspended scaffolds, those elevated temporary platforms that are supported by non-rigid means such as ropes?  Do they need foundations?  You may want to answer no since the rigging that supports the rope is typically on the roof of the structure.  But you would be wrong.  While the word foundation is typically used to describe the lowest level of a building and is usually in the ground, for scaffolding it means much more than that.  Think in terms of Webster’s definition for a base: “a bottom support; that on which a thing stands or rests.”  In the case of suspended scaffolds, the “thing” is the rigging, such as a cantilever beam, while the “bottom support” is the roof of the building or other structure supporting the rigging.  In other words, all scaffolds need foundations; it’s just that the foundation for suspended scaffold may be on the roof of the building.

This brings us to an interesting question about the strength of foundations: what safety factor is required for scaffold foundations?  Should it be adequate as specified in the federal Occupational Safety & Health Administration (OSHA) Construction Industry supported scaffold standards or should it have a safety factor of four as specified in the capacity standards?  But  wait, there’s more!  The OSHA Construction Industry suspended scaffold criteria specifies that “all suspension scaffold support devices, such as outrigger beams, cornice hooks, parapet clamps, and similar devices shall rest on surfaces capable of supporting at least 4 times the load imposed on them by the scaffold operating at the rated load of the hoist (or at least 1.5 times the load imposed on them by the scaffold at the stall capacity of the hoist, whichever is greater.)” [29 CFR 1926.451(d)(1)]  For suspended scaffolds this means the supporting surface, such as the roof of a building, should have a safety factor of 4.  For example, if you had a 1,000 pound load supported by a beam that cantilevered 18 inches past the edge of the roof, and the beam had a backspan of 10 feet, the fulcrum load would be 1,150 pounds while the required counterweight at the back of the beam for such a situation would have to be 600 pounds.  In our example the roof would have to support 1,750 pounds of actual weight.  This is like parking a couple of Harley Davidson Electra Glide Classics on the roof.  Picture that in your mind!  Frankly, my experience suggests that not too many suspended scaffold erectors give this loading thing much thought.  But then, they probably don’t think about parking Harleys on the roof either.  Applying a safety factor of 4, the roof would have to support 4,600 pounds at the fulcrum.  That’s a lot of load.  At the back end of the beam the roof would have to support 2,400 pounds meaning that the roof would have to support 4,000 pounds + 2,400 pounds for a total of 6,400 pounds.  In other words, the roof would have to hold the equivalent of a Chevy Crew Cab pickup truck.  Is this really necessary?  How many roofs do you think can hold a load of this magnitude?  Do the standards really require this?

While the snappy quick answer may be yes, the best way to answer this is to determine what the hazard is and what the intent of the standard is.  The hazard, of course, is that the roof collapses under the load of the hoist.  Therefore, the intent of the standard is to make sure you don’t collapse the roof while using a suspended scaffold; not a bad reason for having the regulation.  The tricky part is how to determine if the roof will have a 4 to 1 safety factor against collapse.  Related to that question is determining how much of the roof you can use to support the rigging.  Since the fulcrum is often a point load, there is a real possibility of having the fulcrum poke a hole in the roof.  That would not be good.  Therefore, this load has to be spread out.  The same may hold true for the back end, depending on how the counterweights are rigged.

Most outrigger applications are designed by “experience,” that is gut feel as to the strength of the roof.  If the roof happens to be new concrete, your gut just might be right.  On the other hand, if the roof is a hundred years old and decayed, your gut may not be right at all and you’ll get indigestion, not to mention what the roof might be doing.

The bottom line is that, just like the rigging, the supporting surface (the roof) must also have a safety factor of 4.  In our previously mentioned example, the actual load that has to be supported is 1,750 pounds, two Harleys.  Depending on the roof construction, for example the direction of the support beams and the design live load, you may be okay.  For illustration, if the roof design live load is 20 pounds per square foot (psf), and the outrigger beams are spaced at least 20 feet apart, the roof just might work with the required safety factor.  Of course, if the live load includes the design snow load, and it snows, your safety factor will melt away before the snow does!

In other words, if you have been guessing about the roof strength, you may have a correct safety factor —or not.

The Power of the Beam

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The Amazing Inside Story of how a Cantilever Beam Works!

Cantilever beams, also known as outrigger beams, are frequently used to support the end of a rope from which a suspended scaffold hangs.  Have you ever wondered how that beam works, especially if you are on the other end of the rope?  Well, here’s the story.

A cantilevered beam is one component of an assembly that consists of a number of parts and pieces that provide the necessary support for the loads that are hanging on the rope.  The beam is designed to use the advantage of leverage; this reduces the amount of force on the rear end of the beam (that would be the other end from where the rope is connected).  Of course, the beam cannot do the work alone.  It must have support towards the front end and the rear end.  The support at the front is called the fulcrum or front support (that’s clever engineering jargon).  The cantilever of the beam is measured from this front support to the point of rope attachment.  This is a critical dimension since the beam has to be strong enough to transfer the load from the rope back across the fulcrum and then to the rear end.  At the rear end is the other support.  Yep, you guessed it, it’s the rear support, also known as the “inboard end”.  This is where the counterweight is located or where the beam is connected directly to the supporting structure.  Now, in order for the whole system to work, the counterweight has to be big enough, if used, or if the beam is attached directly to the structure holding everything, then the connection has to be strong enough and the structure has to be strong enough.  So, how strong does it have to be, you may ask?  Well, strong enough.

Actually, this is where it gets interesting.  The fulcrum load can get rather large, depending on how much the beam sticks out.  And the counterweight can get pretty big too, particularly since you need four times what is actually required to keep the beam from going over the edge of the building.  Incidentally, don’t tell the erection crew that they are carrying 4 times the required counterweight up the stairs; you’ll have a mutiny on your hands.  Other than make the erection crew work harder, there is a very good reason for the extra counterweight.  In engineering terms it is called the safety factor.  In laymen’s terms, the extra counterweight is for typical jobsite screw-ups, such as overloading the suspended scaffold.

Where can the system go wrong?  Unfortunately, there are several places where the unqualified designer can make a fatal error.  First is in the supporting structure.  If the cantilever beam is installed on the roof, the roof has to hold the load.  I’m always surprised how casual some people can be about the strength of a roof, particularly on an older building or one where the maintenance is lax and structural damage has occurred.  While a structural analysis of the roof is typically not within the scope of the typical scaffold installation, it is also typical that the individual charged with the investigation of the roof’s strength will need an accurate submittal of load information as a result of the scaffold loads on the cantilever beam.

The second opportunity for a fatal error is with the beam itself.  The beam has limits.  Just because the beam is 16 feet long doesn’t mean you can cantilever it 8 feet, or for that matter 15 feet.  Funny things start to happen as a beam is cantilevered; the beam likes to wander sideways out there at the front end where the rope is connected.  While most people expect the beam to deflect, that is, start to droop (another one of those engineering terms) few people expect it to wander.  Unfortunately, like an unsupervised teenager, if it wanders too much it gets into big trouble.  Depending on the shape of the beam, too much sideways wandering can make the beam roll, deflect vertically and fail.  If the scaffold users are lucky, the beam will just fold over and the scaffold occupants will wind up on the evening news.  If unlucky, the beam will break and the scaffold will collapse and fall to the street below.  The good news in this scenario is that assuming the scaffold users are utilizing personal fall arrest equipment, like they are supposed to, they’ll be saved from the fall but will still wind up on the evening news.  Hopefully nobody on the street below will get hit by falling debris.

The third possible fatal error is losing the rear end support.  If counterweights are used, they must be mechanically connected to the beam; that is, the counterweights cannot be precariously stacked on top of the beam or haphazardly wired to the beam.  In fact, the counterweights must be specifically designed for the beam and the connections.  If the beam is directly connected to the supporting structure, not only does the connection hardware have to be strong enough but the roof structure components must be able to support the load.  In many cases this will require the services of a qualified Professional Engineer.

The fourth fatal error involves the lack of knowledge of the designer, erector and/or user.  If any of these participants does not have the training and expertise to correctly complete his or her obligations to the project, disaster can occur.  Qualified design is essential; correct installation, according to the design, is imperative; pre-workshift inspections of the rigging are crucial, and; correct scaffold usage, by trained workers, is critical to the safety of the project.

The fifth fatal error, which follows from the fourth fatal error, is lack of training.  All the equipment in the world won’t save you from an early demise if you do not know how to use it.  Training is the key!  And, where can you get that training?  Go to for starters.

Kept in Suspension

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

A review of the standards proves that using a suspended scaffold, such as a two point suspension scaffold typically used for high rise building maintenance and repairs, isn’t any more dangerous than walking down the street that is below it.  In fact, I surmise that a perusal of statistics will show that walking down the street is probably more hazardous than working on a suspended scaffold.  Check out the standards; suspension ropes have to be six times stronger than the load that will be on them.  How can these ropes possibly break?  Obviously somebody is misbehaving.  Is it you?  How well do you know the standards?  Here is a quiz to test your understanding of the federal OSHA standards regarding suspended scaffolds, those scaffold platforms supported by ropes or other non-rigid means.  (Do you suppose the workers who installed the suspended scaffold in the photo would ace this quiz?)

True or False:

  1. The minimum safety factor for suspended scaffold components is 6.
  2. It is permissible to use u-bolts for rope connections supporting workers as long as there are at least three u-bolts.
  3. Outrigger beams can only stick out from the face of the building 24 inches.
  4. Multi-point suspended scaffold users are not required to utilize personal arrest equipment in addition to a guardrail system.
  5. All workers on a multi-level two point suspended scaffold must wear personal fall arrest equipment and be tied off to individual vertical lifelines.
  6. An adjustable scaffold is a suspension scaffold if the mechanical back-up anti-fall dog (level) is inoperable.
  7. All suspended scaffold platform users suspended over water must have life preservers.
  8. All suspended scaffold platform users suspended over water must have at least one lifesaving skiff.
  9. Counterweights for cantilever beams can be water, if frozen, or Jello®.
  10. Counterweights shall not be removed from the beam until the scaffold is disassembled.

Fill in the blank:

  1. All outrigger beams not stabilized by direct connections shall be secured by ________.
  2. When wire rope clips are used on suspension scaffolds, there shall be a minimum number of _________ clips per connection.
  3. Suspension scaffolds shall be inspected before each __________ by a ________ person.
  4. Two point suspension scaffold platforms shall be no more than ________ inches wide unless designed by a qualified person.
  5. The toprail height on a two point suspended scaffold shall be between ______ inches and ________ inches.
  6. The toprail strength on a two point suspended scaffold shall be at least _____ pounds.
  7. All suspended scaffold users shall be trained by a __________ person.
  8. The minimum anchor strength for the personal fall arrest anchor is _______ pounds unless designed by a ___________ person and maintains a safety factor of at least _______.
  9. If an outrigger beam cantilevers 24 inches beyond the fulcrum and the centerline of the counterweight is 12 feet behind the fulcrum, and the load on the suspension rope is 1,000 pounds, the counterweight must be ___________ pounds.
  10. All suspended scaffold installations must be done under the supervision of a _______ person _______ in scaffold erection, using _________and ___________ persons.
  11. Counterweights shall be secured by a _____________ means to the outrigger beam to prevent accidental displacement.

The answers are on page xxxx.  There is no pressure here but remember: you pass if you get all the answers correct and you fail if you get from 1 to 21 wrong; OSHA doesn’t permit partial compliance!


  1. F
  2. F
  3. F
  4. T
  5. F
  6. T
  7. T
  8. T
  9. F
  10. T
  12. 3
  14. 36
  15. 36 AND 45
  16. 100
  18. 5000, QUALIIED
  19. 667 POUNDS



How Well Do You Know?

By | Hoists, Resources, Scaffolding | No Comments

How well do you know the minimum expectations for the construction and use of suspended scaffolds?  Take the following quiz two ways; first answer the questions without referring to any standards or regulations.  Second, answer the questions using any reference material you want.  In other words, take the quiz “closed book” and then take it again “open book.”  The correct answers will be in next month’s magazine so you have 30 days to answer the quiz!


True or False

  1. A suspended scaffold shall be designed by a competent person.
  2. All suspended scaffolds must have at least a 3 to 1 safety factor.
  3. Counterweights for suspended scaffolds must have a 4 to 1 safety factor.
  4. Suspension ropes for suspended scaffolds must be steel.
  5. The material used to make suspension ropes for suspended scaffolds must be certified by the American Wire Rope Association.
  6. Counterweights for suspended scaffold outrigger beams can be sand if it is in a sealed container.
  7. Masons multi-point scaffolds can use counterweights provided they are non-flowable material.
  8. Tieback cables shall be at least as half as strong as the suspension rope.
  9. Outrigger beams can never extend more than 48 inches beyond the fulcrum unless designed by a qualified person.
  10. Repaired wire rope can be used as a suspension rope if it has been repaired by a certified wire rope repairer.
  11. Ropes shall be inspected for defects by a competent person prior to each work shift.
  12. U-bolts can be used on scaffold suspension wire ropes provided they are tight.
  13. There shall be at least three wire rope clips used on wire ropes at their connection points.
  14. Manually operated hoists shall require a positive crank force to descend.
  15. Once the rigging system has been installed and inspected, it shall be inspected weekly unless the system has been overloaded.
  16. Personal Fall Arrest Equipment shall be used on all multi-point suspended scaffolds.
  17. When vertical lifelines are used on a single level, two point suspended scaffold, the lifeline shall be attached to a secure location on the scaffold.
  18. Trained and experience workers do not have to use personal fall protection on two point suspended scaffolds if there is a guardrail system.
  19. Suspended scaffold hoist operators need more training than other workers on a suspended scaffold platform.
  20. While a good idea, a retrieval plan for dangling workers is not required on a suspended scaffold platform that is designed by a qualified person.
  21. Platforms on two-point suspended scaffolds can never be more than 36 inches wide.
  22. Welders working from a suspended scaffold should be concerned about special requirements for protecting the rigging.
  23. Suspended scaffold erectors do not have to use personal fall arrest equipment unless the building is more than 5 stories (48 feet) tall.
  24. If u-bolts are used on suspension ropes, there shall be at least 4 so that there is a 4 to 1 safety factor.
  25. All suspended scaffolds, single, two-point, and multi-point, shall have a guardrail system.
  26. Outrigger beams used for a mason’s multi-point suspended scaffolds shall be designed by an engineer experienced in such scaffold design.
  27. Suspension ropes shall be replaced if more than 6 randomly distributed wires in one rope lay are broken.
  28. Only power operated hoists that support two or more workers require an overspeed brake.
  29. Manually operated hoists can “free-fall” if the operator is trained in this type of operation.
  30.  While erectors shall have special training, users of suspended scaffolds do not require specialized training on the use of suspended scaffolds if they are experienced.
  31. The SIA can provide erectors and users of suspended scaffolds with a recognized training program.


Fill in the blank:

  1. All suspended scaffolds shall be inspected by a _______________ person.
  2. A scaffold supported by a wire rope is classified as a ___________ scaffold.
  3. When a u-bolt is used, the u-bolt shall be placed over the ________ end of the rope.
  4. A minimum of ___________ wire rope clips shall be used on suspended scaffold connections.
  5. I think I got ______________ of the questions correct.


Taking this quiz “closed book” simulates actual jobsite conditions when you try to remember the regulations without any reference material at hand.  “Open book” testing simulates having the reference but perhaps not understanding the intent of the regulations.  Next month we’ll look at the answers to the questions.