Five popular Scaffolding interpretations from OSHA (29CFR1926.450, Subpart L).

Question 1: When may the space between scaffold planks or between scaffold planks and uprights exceed one inch in width?

Answer: The relevant standard, 29 CFR §1926.451(b)(1)(i), states:

Each platform unit (e.g., scaffold [...]]]> For information on fall protection, see OHShub.com’s Post , Fall Protection Guidelines.

Five popular Scaffolding interpretations from OSHA (29CFR1926.450, Subpart L).

Question 1: When may the space between scaffold planks or between scaffold planks and uprights exceed one inch in width?

Answer: The relevant standard, 29 CFR §1926.451(b)(1)(i), states:

Each platform unit (e.g., scaffold plank, fabricated plank, fabricated deck, or fabricated platform) shall be installed so that the space between adjacent units and the space between the platform and the uprights is no more than 1 inch (2.5 cm) wide,except where the employer can demonstrate that a wider space is necessary (for example, to fit around uprights when side brackets are used to extend the width of the platform).  (Emphasis added).

In addition, 29 CFR §1926.451(b)(1)(ii) states:

Where the employer makes the demonstration provided for in paragraph (b)(1)(i) of this section, the platform shall be planked or decked as fully as possible and the remaining open space between the platform and the uprights shall not exceed 9 ½ inches (24.1 cm).  (Emphasis added).

Question 2: Scenario: Employees are on a supported scaffold during erecting and dismantling. While on the scaffold they are using 100% fall protection by being tied off at all times. Under this scenario is there a requirement to have guardrails when on the scaffold’s wooden planks?

Answer: No. Section 1926.451(g)(2) states in part:

… the employer shall have a competent person determine the feasibility and safety of providing fall protection for employees erecting and dismantling supported scaffolds. Employers are required to provide fall protection for employees erecting or dismantling supported scaffolds where the installation and use of such protection is feasible and does not create a greater hazard.

In this scenario fall protection is already being used. There is no additional requirement to have guardrails.

Question 3: Do the OSHA standards prohibit tying off to a scaffold?

Answer: No.

It is OSHA’s position that scaffolding can function as a suitable anchorage for fall arrest systems when the scaffolding section so used is erected and braced such that the criteria of §1926.502(d)(15) are met. This applies whether the scaffold is partially built (i.e., being erected or disassembled) or completely built.

Question 4: Are employees required to wear fall protection while erecting or dismantling scaffolds?

Answer: The Occupational Safety and Health Administration’s (OSHA) policy has been to require fall protection whenever employees are exposed to hazardous conditions meeting the criteria as defined in OSHA Instruction STD 3-3.1, entitled “Fall Protection in Construction: 29 CFR 1926.28 and 105(a)” (copy enclosed). A recent court case involving Spartan Rigging Corporation and Atlantic Rigging Corporation, as outlined in the Occupational Safety and Health Reporter, supports our position that OSHA require at times the use of guardrails or safety belts in dismantling scaffolds. In summary, the Court decided that the absence of fall protection to employees working at intermediate levels of scaffolds posed a hazard capable of serious physical harm or death. Tying employees off could be achieved in a matter of seconds and the wearing of safety belts in dismantling of scaffolds was feasible and did not pose a greater hazard than not wearing them.

Question 5: “I teach a six-day program on scaffolds. In that course, I stress to the participants that their successful completion of the program will not assure their status as a “competent person” under Subpart L — Scaffolds. Conversely, an advertisement for a one-day scaffolding class that I read in a scaffolding magazine indicates that participants who pass that course will have met OSHA requirements for a competent person designation. Can such a claim be valid?”

Answer: The standard does not specify particular training requirements for competent persons. Instead, it defines a competent person in terms of capability.

Thus, successful completion of a course does not, alone, necessarily establish an individual as a “competent person” for a number of reasons. By its terms, the definition of a “competent person” compels the employer to select an employee based upon his or her capability to identify hazards. The course may not be sufficiently comprehensive with respect to the information needed to meet the knowledge requirement in the definition. Remember that the type and extent of the knowledge will vary with what is necessary to successfully perform the task required of the competent person in the standard. Also, the course may not adequately test the employee’s understanding of the course material.

Finally, the definition of a competent person requires the individual to have the authority to take prompt corrective action. No course can provide that authority, since it can only be provided by the employer.

Participants are requested to provide their name, affiliation, [...]]]> OSHA invites interested parties to participate in a Web Chat on June 28, 2010 at 1 pm ET on the workplace hazards of combustible dust. OSHA plans to use the information gathered in response to this Web Chat in developing a proposed standard for combustible dust.

Participants are requested to provide their name, affiliation, and e-mail address so OSHA can respond to comments or seek clarification.

Participants can access the Web Chat at http://www.dol.gov/dol/chat.htm. The Web Blog will remain accessible for additional feedback through July 7, 2010.

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OSHA takes industrial hygiene samples as part of its compliance monitoring program. Many of these samples are submitted to the Salt Lake Technical Center for analysis. Sampling data represent personal, area, and bulk samples for [...]]]> OSHA recently released 25+ years worth of industrial hygiene sampling data as a part of the “Open Government” initiative.

OSHA takes industrial hygiene samples as part of its compliance monitoring program. Many of these samples are submitted to the Salt Lake Technical Center for analysis. Sampling data represent personal, area, and bulk samples for various airborne contaminants.

Personal sampling results represent the exposure to the individual who was actually wearing a sampling device. Area samples are taken in a fixed location and results may represent the potential risk from airborne contaminants or physical agents to workers in that area. Bulk samples were taken to verify if certain constituents are present and if so, in what concentration. Bulk samples are used individually or in conjunction with personal or area samples to help interpret the level of worker risk.

OSHA compliance officers do not:

• Routinely visit every business which use chemicals known to be toxic.

• Take representative samples of every employee and every activity on every day.

• Always obtain a sample for an entire (8-hour) period or shift.

OSHA compliance officers do:

• Target and visit certain industries based on National and regional emphasis programs.

• Have limited time to conduct an inspection and cannot completely characterize all exposures for all employees, every day.

• Use professional judgment and often attempt to evaluate worse case chemical exposure scenarios.

• Develop a snapshot picture of potentially hazardous chemical exposures and use field evaluation tools to assess their significance: often comparing their measured airborne concentrations of chemicals against established standards.

Source:  OSHA.gov

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OSHA recently sent out 15,000 letters to workplaces with the highest DART (days away, restricted, transferred) rates.  (For a DART calculator, see OHShub.com’s post HERE).  For every 100 full-time workers, the 15,000 employers had 4.5 or more injuries or illnesses which resulted in days away from work, restricted work or job transfer. The [...]]]>

OSHA recently sent out 15,000 letters to workplaces with the highest DART (days away, restricted, transferred) rates.  (For a DART calculator, see OHShub.com’s post HERE).  For every 100 full-time workers, the 15,000 employers had 4.5 or more injuries or illnesses which resulted in days away from work, restricted work or job transfer. The national average is 2.0.

Suggestions provided by OSHA to reduce the DART rate included:

• Hiring an outside safety and health consultant
• Talking with your insurance carrier, or
• Contacting your state’s workers’ compensation agency for advice

A copy of the letter is available HERE.

For a list of the 15,000 workplaces, click HERE.

Source: OSHA.gov