Safety for Contractors Scaffolding – OSHA Scaffolding Regulations

Scaffolding is a primary way to reach and work at heights on construction sites. However, the proper use of scaffolding on jobsites generates a lot of concern and questions. Eight of those frequently asked questions are answered here.

1. Are guardrails required on all open sides of scaffolding?

OSHA’s scaffolding standard requires employers to protect each employee on a scaffold more than 10 feet above a lower level from falling to that lower level [1926.451(g)(1)].

Install guardrails along all open sides and ends before releasing the scaffold for use by employees, other than the erection and dismantling crews [1926.451(g)(4)(i)]. The site’s competent person will determine if the erection and dismantling of scaffolding requires fall protection [1926.451(g)(2)].

However, guardrails are not required in the following instances:

• The front end of all platforms is less than 14 inches (36 cm) from the face of the work [1926.451(b)(3)]           
• Outrigger scaffolds are 3 inches (8 cm) or less from the front edge [1926.451(b)(3)(i)]
• Employees are plastering and lathing 18 inches (46 cm) or less from the front edge [1926.451(b)(3)(ii)]

2. When is a scaffolding “competent person” required?

OSHA’s scaffolding standard defines a competent person as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions, which are unsanitary or hazardous to employees, and who has authorization to take prompt corrective measures to eliminate them.”

The scaffolding standard requires a competent person to perform certain duties under circumstances described below.

In General:

• To select and direct employees who erect, dismantle, move or alter scaffolds [1926.451(f)(7]
• To 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 [1926.451(f)(3)] (Note: Windscreens should not be used unless the scaffold is secured against the anticipated wind forces imposed.) 

For Training:

• To train employees involved in erecting, disassembling, moving, operating, repairing, maintaining or inspecting scaffolds to recognize associated work hazards [1926.454(b)]

For Inspections:

• To 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 [1926.451(f)(3)]
• To inspect ropes on suspended scaffolds prior to each workshift and after every occurrence which could affect the structural integrity and to authorize prompt corrective actions [1926.451(d)(10)]
• To inspect manila or plastic (or other synthetic) rope being used for toprails or midrails [1926.451(g)(4)(xiv)]

For Suspension Scaffolds:

• To evaluate direct connections to support the load [1926.451(e)(9)(i)]
• To evaluate the need to secure two-point and multi-point scaffolds to prevent swaying [1926.454(b)]

For Erectors and Dismantlers:

• To determine the feasibility and safety of providing fall protection and access [1926.451(b)(10)]
• To train erectors and dismantlers to recognize associated work hazards [1926.451(b)(11)]

For Scaffold Components:

• To determine if a scaffold will be structurally sound when intermixing components from different manufacturers [1926.451(b)(10)]
• To determine if galvanic action has affected the capacity when using components of dissimilar metals [1926.451(b)(10)]

3. How often must scaffolding be inspected?

OSHA requires [1926.451(f)(3)] that before each work shift and after any occurrence that could affect the structural integrity, a competent person must inspect the scaffold and scaffold components for visible defects.

4. What are the capacity requirements for all scaffolds?

According to 1926.451(a)(1), each scaffold and scaffold component must support, without failure, its own weight and at least four times the maximum intended load applied or transmitted to it.

OSHA also says that a qualified person must design the scaffolds. There are two options for the loading of the scaffold. Use the option that produces the smaller load rating:

• Loading according to the design of the qualified person

          or

• Loading that doesn’t exceed the scaffold and scaffold components maximum intended loads or rated capacities [1926.451(a)(6)]

5. Can you use forklifts, front-end loaders or similar equipment to support platforms?

Forklifts can support platforms only when the entire platform is attached to the fork and the forklift does not move horizontally when workers are on the platform [1926.451(c)(2)(v)].

Front-end loaders and similar equipment can support scaffold platforms only when they’ve been specifically designed by the manufacturer for such use [1926.451(c)(2)(iv)]. This is also addressed in an OSHA Letter of Interpretation dated September 30, 1999, “Forklifts in construction: Elevating personnel and operator training.”

6. What are the requirements for scaffold planking?

Scaffold planking must be able to support, without failure, its own weight and at least four times the intended load [1926.451(a)(1)].

Solid sawn wood, fabricated planks and fabricated platforms may be used as scaffold planks following the recommendations by the manufacturer or a lumber grading association or inspection agency.

Tables showing maximum permissible spans, rated load capacity and nominal thickness are in Appendix A(1)(b)  and (c) of 1926.451(a)(1).

7. How long can materials be stored on a scaffold?

The short answer-one shift. One of the requirements under  1926 Subpart H “Materials Handling, Storage, Use and Disposal” states:  “Materials shall not be stored on scaffolds or runways in excess of supplies needed for immediate operations.”

Storing materials, on scaffolds several days in advance of work activities, or storing materials on scaffolds overnight in preparation for the next day, is prohibited. For purposes of 1926.250(b)(5), “immediate operations” means work that will be done in the shift.

Some provisions in the actual scaffolding standard would be difficult to meet if materials other than those needed for one shift are stored on a scaffold.

For example, 1926.451(f)(3) states: “Scaffolds and scaffold components shall be inspected for visible defects by a competent person before each work shift, and after any occurrence which could affect a scaffold’s structural integrity.”

8. Does OSHA require retraining in scaffolding use?

OSHA says retraining is required in any of the following situations [1926.454(c)]:

• Where changes at the worksite present a hazard about which an employee has not been previously trained
• Where changes in the types of scaffolds, fall protection, falling object protection or other equipment present a hazard about which an employee has not been previously trained
• Where inadequacies in an affected employee’s work involving scaffolds indicate that the employee has not retained the requisite proficiency

Why Be Concerned About Scaffolding Safety?

Scaffolding set up on a construction jobsite is attracts both the general public and OSHA. The compliance officer will most certainly focus part of the inspection on the scaffolding. That could be why OSHA’s top twenty-five most cited construction citations (for both 2008 and 2009) included eight scaffolding violations. Ask questions and get the correct answers before using scaffolding.

Construction Business Owner, July 2010