Scaffolding Good Practices

A recent scaffolding interpretation from OSHA prods general contractors to ensure subcontractors' safe operations.

IT'S a good idea to monitor OSHA's Standard Interpretations site on a regular basis. You can easily find the site by clicking on the "interpretations" link right from OSHA's www.osha.gov homepage. Although long periods of inactivity are common there, the site's occasional updates are important guides to the agency's enforcement strategy. Construction gets as much attention as any area under OSHA's jurisdiction.

Consider the June 10, 2003, response from OSHA Directorate of Construction Director Russell B. Swanson to Barbara McNeil of The Walsh Group's Northeast Division in Boston, Mass. McNeil had written to the Boston regional administrator in March, asking for an explanation the 29 CFR 1926.250(b)(5) prohibition against storing more materials on scaffolds than are needed for immediate operations. Here is the gist of Swanson's answer:

"One of the requirements in 29 CFR part 1926 Subpart H -- Materials Handling, Storage, Use,and Disposal, is §1926.250(b)(5), which states: 'Materials shall not be stored on scaffolds or runways in excess of supplies needed for immediate operations.'

"Your scenario describes storing masonry units on scaffolds several days in advance of block laying activities as well as storing the units on scaffolds overnight in preparation for the next day. The plain language of §1926.250(b)(5) prohibits the storage activities you describe. For purposes of 29 CFR 1926.250(b)(5), 'immediate operations' means work that will be done in the shift.

"Keep in mind that some provisions in the scaffold 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.'

"[I]f storage of materials for more than one shift would prevent the competent person from inspecting the scaffold before each work shift, there would be a violation of both §§1926.250(b)(5) and 1926.451(f)(3) [the companion requirements for wood platforms]. In most cases, where only an incidental amount of materials are left over at the end of the shift, and they did not interfere with inspecting the scaffold, the violation of §1926.250(b)(5) would be considered de minimis."

Chicago-based Walsh Group is a national general contracting and construction management firm with annual revenues above $1 billion, and Boston is one of its four regional offices. The answer to McNeil's second question offers helpful advice for general contractors seeking to ensure subcontractors' safe operations. The question was, May a controlling contractor require a subcontractor to abide by stricter scaffold safety requirements than those found in OSHA standards?

"Yes," Swanson answered. "OSHA standards are minimum requirements; they do not prohibit employers from imposing more stringent, contractual requirements. For example, in the scenario described in Question 1, the controlling contractor could prohibit the storage of materials on scaffolds even where such storage would be considered only a de minimis violation."

Construction Hazard Resources

Falls are a leading cause of deaths and major injuries in construction. You can find much worthwhile information about scaffolds, falls, ergonomics, confined spaces and trenching, electrical hazards, noise, vibration, and many other construction concerns--offered in a wide variety of languages--by visiting the Electronic Library of Construction Occupational Safety and Health (www.cdc.gov/niosh/elcosh/index.html.)

Other valuable contacts are OSHA's Directorate of Construction (fax 202-693-1689 or mail to U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Ave. NW, Washington, DC 20210); the Houston Training Center of the Scaffold Training Institute (800-428-0162 or www.scaffoldtraining.com); and the Construction Safety Council in Hillside, Ill. (phone 708-544-2082, fax 708-544-2371, or visit www.buildsafe.org).

Construction Safety: Management Issues

Yes

No

Does the person on firewatch have access to a telephone? If so, does he or she know how to use it? Is there a language barrier?

Yes

No

Is the telephone number of the local fire department or emergency medical agency prominently displayed?

Yes

No

Is a routine inspection of the premises made when work has finished, and again at least one hour after work has stopped for the day, to check for slow-burning or smoldering fires? Are portable heating units verified as turned off?

Yes

No

Is someone on the staff at management level responsible for fire prevention measures to resolve differences in opinion and make management decisions?

Yes

No

Is every employee aware of how to escape from the premises?

Yes

No

Does a competent person inspect scaffolds and scaffold components for visible defects before each work shift and after any occurrence that could affect the scaffold's structural integrity?

Yes

No

Does every employee know how to use the fire equipment with appropriate and documented training?

Yes

No

Are all stored materials clear of the floor in an approved location?

Yes

No

If smoking is allowed at specific areas on site, are appropriate receptacles for cigarette butts provided? Are these checked throughout the day and emptied as needed, and again when work is completed? Is an appropriate distance from any combustible materials maintained?

Yes

No

Is there a system of supervision on site for specialty activities, such as welding operations or other hot work that may be carried out on the premises?

Yes

No

Do those doing hot work have appropriate fire extinguishers with them and know how to use them appropriately for the hazard?

Yes

No

Is fire equipment located where it is really needed? Is it easily accessible and in good working condition?

Yes

No

Are the right classes of extinguishers provided for the types of fire that could occur?

This checklist is intended for informational purposes only and is not a substitute for a comprehensive safety program.

This article originally appeared in the October 2003 issue of Occupational Health & Safety.

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