CFR 29 1926.451, Scaffolding, was the #3 most cited standard by OSHA in 2013. If employers had focused their compliance efforts on these sections of the standard, they could have not only reduced
workers’ compensation costs by lessening their employees’ exposure to some extremely serious workplace hazards, but they would have also significantly reduced their risk of receiving a citation.
Immediate supervisors on construction projects should review, investigate, and take any necessary and appropriate action on all employee reports of hazards or potential hazards.
Minimum OSHA Requirements
OSHA dictates that employers in the construction industry provide a safe and healthful workplace, including:
- providing employees with sanitary and safe working conditions
- assigning safety and health responsibilities
- giving safety and health designees authority to correct hazards
- ensuring employees may voice safety and health concerns without fear of reprisal
- informing employees of worksite hazards
- coordinating hazard communication with other employers on site
- posting the OSHA state or federal poster
It's important to understand who is responsible for safety on the construction worksite. According to OSHA, there are four employer roles or categories on a multi-employer worksite.
The creating employer here has erected a defective scaffold and allowed its use.
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- Creating employer: The employer who caused a hazardous condition that violates an OSHA standard. An example would be a contractor who erects a defective scaffold.
- Exposing employer: This is an employer whose own employees are exposed to the hazard. An example would be an employer who allows his own employees to work on a scaffold without proper guardrails.
- Correcting employer: This is an employer who is engaged in a common undertaking, on the same worksite as the exposing employer, and is responsible for controlling or otherwise eliminating a hazard.
This usually occurs when an employer is given the responsibility of installing and/or maintaining particular safety/health equipment or devices such as scaffolds.
- Controlling employer: This is an employer who has general supervisory authority over the worksite, including the power to correct safety and health violations itself or require others to correct them.
Control can be established by contract or, in the absence of explicit contractual provisions, by the exercise of control in practice. An example would be the general contractor who has control over the
erection of scaffolds on the worksite.
Assigning Competent and Qualified Personnel
Assign a competent and qualified persons to oversee the scaffold selection, erection, use, movement, alteration, dismantling, maintenance and inspection. Only assign trained and experienced personnel
to work on scaffolding.
A competent person can identify hazardous working conditions and has authorization to take prompt corrective measures to eliminate them. The competent person, who has primary responsibility for
supervising and directing all scaffolding erection, dismantling, and altering work, should:
- Know Subdivision 3/L requirements applicable to the types of scaffolds used.
- Identify and correct hazards encountered in scaffold work.
- Be trained in the structural integrity of the types of scaffolds used.
- Have authority to promptly abate hazardous worksite conditions.
We'll take a look at the duties of a competent person in the next tab.
Competent Person Duties
A competent person must be able to identify and promptly correct hazards.
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A competent person’s duties can be shared as long as each person is qualified to perform the duty and has authority to correct hazards promptly. Competent persons must be able to do the following:
- Select and direct employees who erect, dismantle, move, or alter scaffolds.
- Determine if it is safe for employees to work on or from a scaffold during storms or high winds and to ensure that a personal fall arrest system or wind screens protect these employees. (Note:
Windscreens should not be used unless the scaffold is secured against the anticipated wind forces imposed.)
- Train employees involved in erecting, disassembling, moving, operating, repairing, maintaining, or inspecting scaffolds to recognize associated work hazards.
- Inspect scaffolds and scaffold components for visible defects before each work shift and after any occurrence which could affect the structural integrity and to authorize prompt corrective actions.
- Inspect ropes on suspended scaffolds prior to each workshift and after every occurrence. This could affect the structural integrity and to authorize prompt corrective actions.
- Inspect manila or plastic (or other synthetic) rope being used for toprails or midrails.
- Evaluate direct connections to support the load.
- Evaluate the need to secure two-point and multi-point scaffolds to prevent swaying.
For Erectors and Dismantlers:
- Determine the feasibility and safety of providing fall protection and access.
- Train erectors and dismantlers to recognize associated work hazards.
For Scaffold Components:
- Determine if a scaffold will be structurally sound when intermixing components from different manufacturers.
- Determine if galvanic action has affected the capacity when using components of dissimilar metals.
Competency = Training Plus Experience
Many employer groups, vendors, apprenticeship programs, and labor organizations offer training on Subdivision 3/L scaffolding requirements. However, attending one of these programs does
not necessarily make one competent (or a competent person). Competency should be demonstrated; it’s usually the result of many hours of in-class training and on-the-job experience.
A qualified person has a recognized degree, certificate, or professional standing — or by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve problems
related to the subject, the work, or the project.
Scaffolds should be designed by a qualified person but not necessarily by an engineer.
Exceptions: Connections for mason’s adjustable multipoint suspension scaffolds, pole scaffolds more than 60 feet high, coupler and fabricated-frame scaffolds more than 125 feet high, and outrigger
scaffolds should be designed by a registered professional engineer.
Qualified Person Duties
- Design and load scaffolds in accordance with that design.
- Train employees working on the scaffolds to recognize the associated hazards and understand procedures to control or minimize those hazards.
For Suspension Scaffolds:
- Design the rigging for single-point adjustable suspension scaffolds.
- Design platforms on two-point adjustable suspension types that are less than 36 inches (0.9 m) wide to prevent instability.
- Make swaged attachments or spliced eyes on wire suspension ropes.
For Components and Design:
- Design scaffold components construction in accordance with the design.
The standard requires a registered professional engineer to perform the following duties in the circumstances.
For Suspension Scaffolds:
- Design the direct connections of masons’ multi-point adjustable suspension scaffolds.
- Design scaffolds that are to be moved when employees are on them.
- Design pole scaffolds more than 60 feet (18.3 meters) in height.
- Design tube and coupler scaffolds more than 125 feet (38 meters) in height.
- Design fabricated frame scaffolds more than 125 feet (38 meters) in height above their base plates.
- Design brackets on fabricated frame scaffolds used to support cantilevered loads in addition to workers.
- Design outrigger scaffolds and scaffold components.
Qualifications for Inspecting Scaffolds
For some types of scaffolds, a competent person should supervise the erection, installation or relocation of scaffolds. If an employee meets the requirements for a competent
person for those purposes, that employee would also be qualified to periodically inspect those scaffolds.
Scaffold Inspection Timeline
There are periodic inspection requirements for a number of different types of scaffolds. "Periodic" means frequently enough so, in light of these factors and the amount of time expected
for their detrimental effects to occur, there is a good likelihood problems will be found before they pose a hazard to employees.
For example, there are periodic inspection requirements for:
- welded frame scaffolds (1910.28(d)(14))
- mason's adjustable multiple-point suspension scaffolds (1910.28(f)(11))
- two-point suspension scaffolds (1910.28(g)(8))
These standards do not specify how often a scaffold should be inspected to meet the "periodic" requirement. However, the company should have a clear policy regarding the frequency of
periodic scaffold inspections. The frequency of periodic safety inspection should depend on factors such as:
- the type of scaffold
- site and weather conditions
- intensity of use
- age of the equipment
- how often sections or components are added, removed or changed
These factors will determine how quickly or slowly safety related faults, loose connections, degradation and other defects can be expected to develop.
Training for Scaffold Inspectors
For the employer to meet this obligation, the employee assigned to do the inspections should have sufficient knowledge to recognize unsafe scaffold conditions and to determine if the
scaffold continues to meet the applicable scaffold standard requirements.
The employer may assign the periodic inspection task to one of its employees using the scaffold only if the employee has this level of knowledge. The employee should understand a cursory
look at the scaffold prior to use would not constitute an inspection - an inspection requires a careful and critical examination.
Emergency Action Plan
In the company’s Emergency Action Plan (EAP) the employer should establish procedures to ensure a worker who falls from a scaffold receives immediate attention. Emergency procedures should be
fully documented before workers begin work or use fall-arrest or restraint systems.
Emergency procedures within the EAP should identify key rescue and medical personnel, equipment available for rescue, communications procedures, retrieval methods, and first-aid requirements.
The following lists identify safe practice guidelines for developing emergency response planning procedures, responding to emergencies, and investigating accidents.
Before on-site work begins
- Make the fire department or emergency responders aware of the job specifications at the site and any factors that may slow response time.
- Create one or more joint training sessions between key on-site personnel and emergency responders.
- Document the rescue plan and make sure it is posted at the worksite.
- Mark the job site with signs and note the easiest access routes into and out of the site.
As on-site work progresses
- Identify on-site equipment (examples: boomlifts, ladders, and forklifts) that can be used for rescue and retrieval.
- Maintain a current emergency equipment inventory at the site. Equipment may change frequently as the job progresses.
- Re-evaluate and update the emergency-response plan if on-site work tasks change.
EAP Actions (Continued)
- Call 9-1-1 or other emergency numbers indicated on the emergency-response plan. Use 9-1-1 for ambulance service but remember that most 9-1-1 responders are not trained to rescue an injured
worker suspended in a personal fall-arrest system. Rescue procedures should ensure prompt response to a suspended worker. The 9-1-1 number does not ensure prompt response. First responders
should clear a path to the victim. Others should be sent to direct emergency personnel to the scene.
- Make sure only qualified personnel attempt a technical rescue.
- Prohibit all nonessential personnel from the rescue area.
- Talk to the victim; determine the victim’s condition, if possible.
- If the victim is accessible, comfort and check vital signs. If necessary, administer CPR and attempt to stop bleeding.
- Do not attempt a solo rescue if the victim is suspended. Wait for trained emergency responders.
Accident investigation guidelines
- Only trained and qualified persons should conduct accident investigations.
- Report fatalities and catastrophes to OSHA within eight hours.
- Report injuries requiring overnight hospitalization to OSHA within 24 hours.
- Identify all equipment associated with the accident and put it out of service until the accident investigation is complete.
- Document the scene, determine the sequence of events, and analyze the surface and root causes.
- Review the fall-protection plan; determine how the plan could be changed to prevent similar accidents; revise the plan accordingly.
- Have a qualified person examine equipment associated with the accident; if damaged, repair or replace it. If it contributed to the accident, determine how and why, then replace it.
- Do not disturb the scene of a fatality or catastrophe.
A Word about Common Sense
There's no such thing as common sense.
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This topic may be a little controversial, and you may not agree, but in a word, common sense is quite "uncommon." It's common to hear someone say, "he should have used common sense about that," but it's never really appropriate to make that assumption. Actually, everyone has either a unique "good sense" or "poor sense" about what is appropriate or safe. We each gain a certain sense about things be based on our unique personal genetics, previous personal experience, and training.
Using the "common sense" excuse for accidents makes it easy to prematurely blame the worker. It's also a way to quickly divert possible personal blame on oneself from being considered. Before making a judgment and blaming the worker, it is important for managers to first analyze the company's safety management system to rule out failures in planning, policies, programs, processes, procedures, and safe-practices that might have contributed to the accident. Only after system failures have been ruled out, should discipline for intentional non-compliance be considered. For more information check out the article Common Sense is Neither Common nor Sense, by Jim Taylor Ph.D.
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