What We Saw in the Picture
Last week we showed you this picture and asked what you saw that was right and what was not right.
Picture courtesy of ECLOSH.
- The scaffold looks like it was not built according to regulatory requirements.
- The workers are not wearing PPE, including fall protection.
- The site looks like a mess, with scraps, trip hazards, and equipment left laying around.
- We are hoping that the A-frame ladder leaning against the structure in the lower right corner is just being stored there and is not used to reach the upper levels of the scaffold.
- The openings in the building appear to be windows. They must have guardrails to protect anyone working inside.
You may have found more things that concerned you.
While it is difficult to know for sure, it appears that the first rule of scaffolds may have been violated, that a “qualified person” must design the scaffold. A qualified person is defined as someone who “by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” (29 CFR 1926.32)
Some additional requirements for scaffolds include, but are not limited to:
- 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. 1926.451(a)(1)
- Each scaffold platform and walkway must be at least 18 inches (46 centimeters) wide. When the work area is less than 18 inches (46 centimeters) wide, guardrails and/or personal fall arrest systems must be used. 1926.451(b)(2)
- The standard requires employers to protect each employee on a scaffold more than 10 feet (3.1 m) above a lower level from falling to that lower level. 1926.451(g)(1)
- To ensure adequate protection, 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)
OSHA has specific requirements for guardrails (not seen in the picture) that are found in 1926.502. While there are more requirements than these, here are a few that should be kept in mind:
- Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria of this paragraph.
- Midrails, when used, shall be installed at a height midway between the top edge of the guardrail system and the walking/working level.
- Other structural members (such as additional midrails and architectural panels) shall be installed such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.
- Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge.
One last thought to pass along. There are 28 states and territories that have their own set of requirements. They are called “State Plan States.” California, where SCM is based, is one of them. We are pretty sure that even the State Plan States would not sanction the scene in our picture, however, check with your state’s regulatory requirements.