Citations for violating scaffolding requirements consistently make it onto OSHA’s annual Top 10 list. The requirements are in 29 CFR 1926.451(a) through (h). In Part 5 of this series on scaffolding safety, we look at the requirements for scaffold access [29 CFR 1926.451(e)].
Employees are not expected to climb up the crossbraces to access a scaffolding platform; you must provide some other means [29 CFR 1926.451(e)(1)] whenever the platform is more than 2 ft above or below a point of access. That means will be some kind of ladder (e.g., hook-on and attachable ladders), stair tower, ramp, or walkway. Access can also be provided by integral prefabricated means or direct access from another scaffold, personnel hoist, or similar surface.
The rules for hook-on and attachable ladders are in 29 CFR 1926.451(e)(2)(i) through (vi). For example, they must be positioned so their bottom rung is no more than 24 inches above the scaffolding support level.
The rules for stairway-type ladders are in 29 CFR 1926.451(e)(3)(i) through (iv). For example, the minimum step width is 16 in., except for mobile scaffold stairway-type ladders (11.5 inches).
The rules for stairtowers are in 29 CFR 1926.451(e)(4)(i) through (xiv). With so many rules, you have a fairly high risk of error. But many of these have to do with the rails, handrails, and guard rails. Several can be summed up to, “Ensure the rail doesn’t cut or impale the worker.” You’ve got some minimum and maximum distances to observe; for example, handrails must be at least three inches from other objects. There are other requirements, such as uniformity of riser height and uniformity of tread depth.
The rules for ramps and walkways are in 29 CFR 1926.451(e)(5)(i) through (iii). For example, ramps and walkways 6 ft or more above lower levels must have guardrail systems that comply with Part M (Fall Protection).
The rules for integrated prefabricated access frames are in 29 CFR 1926.451(e)(6)(i) through (vi). For example, they must be uniformly spaced within each frame section.
Steps and rungs of ladder and stairway type access must line up vertically with each other between rest platforms [29 CFR 1926.451(e)(7)]. Direct access to or from another surface can be used only when the scaffold is not more than 24 in. vertically from either surface [29 CFR 1926.451(e)(8)].
29 CFR 1926.451(e) ends with the rules for access by employees erecting or dismantling supported scaffolds [29 CFR 1926.451(e)(9)(i) through (iv)]. The crux of these rules is the employer must provide a safe means of access for each employee erecting or taking down scaffolding. This excludes forcing them to climb the crossbraces or stand on the tubular frames. There is room for judgment in this last set of requirements because sometimes safe access is infeasible or would create a greater hazard.
That judgment can be made only by a competent person by which OSHA means someone who is competent in this particular area. It’s not implied or stated here that some kind of other accommodation would be made to improve the situation, but any ethical manager, supervisor, or company executive would see what could be done along those lines.