Preventing Scaffolding-Related Citations, Part 6

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 6 of this article series, we look at the requirements that pertain to how scaffolding is used [29 CFR 1926.451(f)].

The first rule is you can’t load scaffolds or components beyond their maximum intended loads or rated capacities, whichever is less. There are sixteen other enumerated rules, (2) through (17).

Rule 15 prohibits using ladders on scaffolds to increase the working level height. But there’s an exception for large area scaffolds that meet the criteria enumerated in (i) through (iv).

Rule 17 exists to reduce the possibility of welding current arcing through the suspension wire rope when welding from suspended scaffolds. It enumerates six precautions in (i) through (vi). For example, cover each hoist with insulated protective covers.

Some of the other rules are just common sense. For example, don’t let debris accumulate on platforms [29 CFR 1926.451(f)(13)]. Or the rule that says not to work on scaffolds during storms or high winds [29 CFR 1926.451(f)(12)] with an exception being made by a competent person AND the necessary personal protective equipment (PPE) is used.

Others are not so obvious. For example, platforms cannot deflect more othan 1/60^th of the span when loaded [29 CFR 1926.451(f)(16)].

Question: What’s the minimum distance at which scaffolding can be relative to an insulated 480V power line? The answer is 10 ft, and you can find that in the table under 29 CFR 1926.451(f)(6).

Now what’s especially interesting about 29 CFR 1926.451(f) is these rules can be broken only by the employees who are using the scaffolding but the company itself is subject to OSHA citations and fines. At first blush, this seems unfair. But the onus is always on the employer to provide training in (and enforcement of) its safety program. The presumption is that an employer who is diligent about this won’t have problems with employees routinely violating such rules.

An OSHA inspector will have one reaction to a site where their replacement safety glasses are readily available and everybody but that one guy is wearing them, and an entirely different reaction to a site where half the people don’t even have safety glasses. Guess which of the two is likely to get the heaviest possible fine? So it is with scaffold use.

Individual employees will make mistakes when using scaffolding. What is the response of management? A proper response could include anything from updating the training to better address that error to terminating the employee who disregards the rules one time too many.

The worst possible response is to ignore or downplay employee errors or (more seriously) employee disregard for the rules. That’s not because of an increased risk of an OSHA fine; it’s because of an increased likelihood that behavior will get somebody killed. A mix of responses usually works best. For example, stop the employee, and discuss the unsafe act. If the employee is a repeat offender, go with progressive discipline. Check the training for inadequacy in content and frequency.

It can be helpful to have a “safety talk” before the shift ends to highlight this issue. This technique can be very effective if the employee who made the mistake can briefly share with the crew what he did wrong and what is the right way. This is not as punishment, but an act as someone who just learned something that can help everyone.

Finally, always encourage scaffold users to keep an eye out for each others’ safety. Not that management is delegating this, but that management makes scaffold safety a team effort.