It is well-known among roofing professionals that the Occupational Safety and Health Administration's (OSHA's) most commonly issued citation against employers in the roofing industry is for fall-protection infractions. However, infractions involving scaffolds and ladders also are among OSHA's most commonly issued citations and have unique sets of requirements.
Unlike fall-protection requirements under Subpart M of OSHA's construction regulations, fall-protection issues related to scaffold use are controlled by Subpart L. This causes a fair amount of confusion among roofing professionals.
Subpart L addresses fabricated (tubular) frame scaffolds common at many construction sites, as well as chicken ladders (which OSHA refers to as crawling boards), ladder jacks and pump jack scaffolds. But subpart L's most divergent and critical requirement is related to worker fall protection on scaffolds.