Preventing Scaffolding-Related Citations, Part 1

Citations for violating scaffolding requirements consistently make it onto OSHA’s annual Top 10 list. The requirements are found in 29 CFR 1926.451(a) through (h). All of these are under the subhead General Requirements. There are no other subheads. That means all of these requirements apply to scaffolding generally.

This is a bit anomalous and confusing because (c) is for supported scaffolds and (d) is for suspension scaffolds. A correct hierarchy would have the General Requirements as 29 CFR 1926.451(a)(1) through (8), with 29 CFR 1926.451(b) for supported scaffolds and (c) for suspended scaffolds. Also, some of the other general requirements apply to only a specific type of scaffold.

OSHA will probably remedy this in the next revision, but the error doesn’t materially affect the understanding and application of the requirements. You just need to do a small mental shuffle — which, for people smart enough to be qualified for electrical work, is not a big ask.

In Part 1 of this article series on preventing scaffolding-related OSHA citations, we look at the capacity requirements [29 CFR 1926.451(a)]. There are six of them.

1. Each scaffold and component must be capable of supporting its own weight and at least four times the maximum intended load applied or transmitted to it. Notice the use of “component.” Every bolt, connector, toeboard, brace, and plank must meet this requirement. Notice also that OSHA does not specify a loading direction. Nothing here says “downward force.” This means those components and the assembly itself must also be able to withstand four times the anticipated lateral force.
2. If you connect an adjustable suspension scaffolding to a floor, counterweight, etc., the direct connections must be able to resist four times the tipping moment imposed by the scaffold.
3. Each connecting rope (including connecting hardware) used on non-adjustable suspension scaffolds must be able to support at least six times the intended load applied or transmitted to that rope.
4. Each connecting rope (including connecting hardware) used on adjustable suspension scaffolds must be able to support at least six times the intended load applied or transmitted to that rope or at least two times the stall load of the hoist, whichever is greater.
5. The stall load of any scaffold hoist shall not exceed three times its rated load.
6. Scaffolds shall be designed by a qualified person. They shall be constructed and loaded per that design.

If you look again at the six requirements, you can see plenty of opportunity for error that may result in a citation. And even worse, a single error may result in multiple fatalities. It isn’t OSHA’s job to catch your errors and thus protect your employees. OSHA samples only a tiny portion of all scaffolding in use throughout the country at any given moment. It is your job to design out errors in your procedures and then to implement good inspection practices to catch errors that are made. When an error is discovered, go back to your procedures and try to design it out.

Capacity errors are often a result of applying the math incorrectly. One way to eliminate most — or even all — such errors is to standardize on a core design that will suffice for all of your anticipated work. This means it will be overdesign for many projects. To hold costs down, you can use administrative controls. For example, no more than two people on a scaffold at any one time. Or this standard system cannot be used for projects involving motor replacement or any equipment weighing more than X pounds.