OSHA’s Top 10 List of Most Frequently Cited Standards: Scaffolding
Posted on January 10, 2024 | in EHS
Continuing our rundown of OSHA’s Top 10 List of Most Frequently Cited Standards for 2023, we’ve reached number four, OSHA’s Scaffolding Standard.
Working at heights is serious business. The safety risks are higher…quite literally. That’s why the OSHA Scaffolding Standard is such a technically detailed regulation.
OSHA defines a scaffold as, “an elevated, temporary work platform. There are two basic types of scaffolds: Supported scaffolds, which consist of one or more platforms supported by rigid, load- bearing members, such as poles, legs, frames, outriggers, etc.”
It’s obvious that it’s important to keep employees safe when working on scaffolds, yet there were 2,859 citations of the Scaffolding Standard during fiscal year 2023. Moreover, OSHA’s Scaffolding Standard has consistently ranked in the top five on OSHA’s Top 10 List of Most Frequently Cited Standards since at least 2016. So, where are these citations happening, and how can the issues be resolved to help maintain compliance, keep employees safe, and minimize regulatory risks to your business?
What is OSHA’s Scaffolding Standard?
OSHA’s Scaffolding Standard aims to prevent accidents and injuries associated with the use of scaffolds in construction work. The standard provides comprehensive guidelines for the proper erection, use, and disassembly of scaffolding to ensure the safety of workers at elevated heights.
Construction and maintenance work often requires employees to operate at elevated heights, making scaffolding an essential part of these activities. However, work performed on scaffolds can be hazardous if scaffolds are not appropriately erected and used.
Common hazards associated with scaffolds include:
- falls from elevation, due to lack of fall protection
- the collapse of the scaffold, caused by instability or overloading
- being struck by falling tools, work materials, or debris
- electrocution, due to the proximity of the scaffolds to overhead power lines
To protect workers and prevent potential accidents, the OSHA has developed strict regulations regarding scaffolding. In this blog post, we will break down OSHA’s scaffolding standard to understand its key components and ensure that safety remains a top priority in construction and related industries.
General Requirements of OSHA’s Scaffolding Standard
While the OSHA Scaffolding Standard itself is a very detailed document, there are a number of key areas of requirements that we can focus on to help simplify compliance:
Capacity
The capacity requirements within the standard are intended to ensure scaffolds are designed and in sufficient condition to support employees and their tools as they work. It specifies that, “each scaffold and scaffold component shall be capable of supporting, without failure, its own weight and at least 4 times the maximum intended load applied or transmitted to it.”
Scaffold Platform Construction
The platform construction requirements of the OSHA Scaffolding Standard prescribe how scaffolding should be assembled and connected, stating that scaffolding must be “fully planked or decked between the front uprights and the guardrail supports.”
Supported Scaffolds
The most commonly used type of scaffold, ‘supported scaffold requirements cover aspects like scaffold construction, tie-ins, bracing, and the use of devices to prevent scaffold movement.
Suspension Scaffolds
Commonly used in window cleaning and exterior maintenance, OSHA’s standard mandates additional safety measures such as the use of complete and independent support systems, counterweights, and tiebacks to ensure stability.
Access
The standard requires that employees have safe and easy access to all scaffolds for work, whether via portable, hook-on, attached or stairway-type ladders, s or stair towers/rails. The official standard includes specific requirements per each type of ladder/stair and their handrails.
Use
The standard includes specifications for the safest use of scaffolds and scaffold components, such as:
- Scaffolds shall not be loaded in excess of their maximum intended loads or rated capacities—whichever is less.
- Prohibiting the use of shore or lean-to scaffolds.
Fall Protection
The Scaffolding Standard includes requirements for keeping employees safe from fall hazards, such as the use of a personal fall arrest and guardrail systems.
Falling Object Protection
The standard specifies that along with hardhats, “each employee on a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects through the installation of toeboards, screens, or guardrail systems, or through the erection of debris nets, catch platforms, or canopy structures that contain or deflect the falling objects.”
Where are the Citations Happening?
Many aspects of the Scaffolding Standard listed above include their own specific design and construction/erection requirements. It’s very possible—dare we say probable—that in many workplaces where scaffolding is used, that scaffolding may not be to the exact measurements that OSHA specifies in the Scaffolding Standard.
We see that essentially all of the top 5 most cited provisions within the OSHA Scaffolding Standard are related to these design and construction/erection requirements, representing 72% of the 2,859 total violations under the Scaffolding Standard in 2023. These provisions are listed below:
- 1926.451(g)(1): “Each employee on a scaffold more than 10 feet above a lower level shall be protected from falling to that lower level.” –813 violations
- 1926.451(e)(1): “When scaffold platforms are more than 2 feet above or below a point of access, portable ladders; hook-on ladders; attachable ladders; stair towers (scaffold stairways/towers); stairway-type ladders (such as ladder stands); ramps; walkways; integral prefabricated scaffold access; or direct access from another scaffold, structure, personnel hoist or similar surface shall be used. Cross braces shall not be used as a means of access.” –372 violations
- 1926.451(b)(1): “Each platform on all working levels of scaffolds shall be fully planked or decked between the front uprights and the guardrail supports.” –357 violations
- 1926.451(c)(2): “Supported scaffold poles, legs, posts, frames and uprights shall bear on base plates and mud sills or other adequate firm foundation.” –324 violations
- 1926.451(g)(4): “Guardrail systems installed to meet the requirements of this section shall comply with the following provisions (guardrail systems built in accordance with Appendix A to this subpart will be deemed to meet the requirements of paragraphs (g)(4)(vii), (viii) and (ix) of this section).” –190 violations
It’s easier said than done for employers to scour their workplaces to inspect all scaffolding systems, compare each measurement of the standard to what’s present in the worksite, and verify that every piece of the scaffolding system meets the specifications listed in the standard. However, that’s precisely what the Scaffolding Standard requires. With improved methods and processes for overseeing scaffolding construction and inspecting scaffolding systems, and a stronger focus on prevention through design (PtD) of scaffolding systems, many of these types of technical standard violations could be avoided in the future.
The Costs of Non-Compliance
We can see from how often the OSHA Scaffolding Standard is cited, year after year, that OSHA views it an essential regulatory tool for protecting workers from fall-related injuries while working at elevated heights. By adhering to the specifications set forth in the standard, employers can ensure the safety of their workers and minimize the risk of injuries or fatalities in the workplace, while also protecting themselves from civil and potentially criminal liability for non-compliance.
Under the Federal Civil Penalties Inflation Adjustment Act of 2015, fines for non-compliance with federal standards and regulations across all federal executive agencies continue to rise annually. In 2023, OSHA’s maximum penalties for serious and other-than-serious violations increased from $14,502 per violation to $15,625 per violation. The maximum penalty for willful or repeated violations will increase from $145,027 per violation to $156,259 per violation. One of the larger OSHA penalties for Scaffolding Standard violations occurred in 2020 when a scaffolding contractor was fined $300,370 after a laborer fell to his death from a seven-story building. During the investigation, authorities found two willful and two serious safety violations of OSHA regulations. Citations were issued for breaches of fall protection and scaffolding safety standards, as well as failing to adequately train workers about fall risks connected with scaffolding work.
More than the fines and penalties for regulatory violations are the human costs of fall-related injuries, and the value of human lives saved by keeping workers safe from incidents, injuries, and fatalities. Safety should always come first, no matter at what height you’re working. Adherence to OSHA’s Scaffolding Standard not only promotes a safer work environment but also boosts productivity and fosters a positive working culture within the industry and boost the bottom line.
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