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.
Different from the 6-foot trigger height for fall protection at construction sites, fall protection must be in place on scaffolds exceeding 10 feet in height.
For example, once a tubular frame scaffold reaches more than two standard 5-foot sections in height, workers performing work on the scaffold must be protected from falls. This typically is easily accomplished because guardrail components for tubular frame scaffolds are readily available and connect with minimal complication. Workers also have the option of using personal fall-arrest (PFA) systems for fall protection on tubular frame scaffolds; however, the difficulty with this option is installing a suitable anchor point.
Guardrails and PFA systems also are fall-protection options when using pump jack scaffolds though PFA systems have a similar drawback regarding anchor installation. Guardrails typically are the simplest and most common fall-protection device used with pump jack scaffolds because compatible guardrail components are available for most pump jack models.
Fall protection for ladder jacks is limited to using PFA systems, which must be in place when heights exceed 10 feet. Obviously, locating an anchor point for a lifeline in PFA system setup for ladder jacks is a major obstacle. Many contractors are surprised to learn a somewhat obscure OSHA rule that restricts ladder jack use to platform heights of 20 feet or less regardless of workers' use of fall protection.
OSHA provisions related to ladder use are located in Subpart X of OSHA's construction industry regulations. The most common citations related to ladders involve a ladder's improper extension over the landing surface, securing or tying off ladders, and workers' actions while ascending or descending ladders. Unfortunately, not all OSHA regulatory language describing requirements for ladder use is succinct, and confusion may result.
Subpart X calls for a ladder to extend at least 3 feet above the upper landing surface the ladder is being used to access. The ladder can have a lesser extension only if its height does not permit the 3-foot extension, the ladder is tied-off at the top and a secure grab rail is provided. Note that the tie-off requirement does not apply in instances where the ladder extends the full 3 feetthis is confusing and often subject to misinterpretation by workers and OSHA compliance officers. A safer approach may be to train workers to extend a ladder a minimum of 3 feet above the upper contact point and tie it off to a suitably strong anchor point at the top.
Protect your workers
Make sure you train workers with the goal of achieving safe behavior at job sites rather than merely gaining knowledge of OSHA rules. Such an approach will more effectively protect your work force when it comes to OSHA provisions regarding scaffold and ladder safety.
Harry Dietz is NRCA's director of safety compliance.