Safe Solutions

As you probably know, fall protection is the Occupational Safety and Health Administration's (OSHA's) most frequently cited violation in the roofing industry. However, less well-known is the second most frequently cited violation: scaffolding. More than 1,200 scaffolding-related citations were issued in 2008 with more than $1.1 million in penalties.

There is significant scaffold use in roofing, and you should be as well-versed in OSHA's scaffold provisions as you are in OSHA's fall-protection provisions.

OSHA's rules

OSHA's construction scaffold standard, 29 CFR 1926.451, includes requirements for capacity, construction, access, use and fall protection for numerous scaffold types commonly used in the roofing industry. These include tubular welded-frame scaffolds, tube and coupler scaffolds, chicken ladders (or crawling boards as OSHA calls them), ladder jack scaffolds, pump jack scaffolds and suspension scaffolds.

OSHA requires that each scaffold and scaffold component be able to support its own weight and at least four times the maximum intended load to be applied to it. OSHA defines maximum intended load as the total load of all people, equipment, tools, materials and other reasonably anticipated loads, such as wind, applied to a scaffold or scaffold component at any one time. A scaffold's capacity to withstand loads is critical in roofing work considering the substantial weight of some roofing materials, such as rolls of polymer-modified bitumen or bundles of architectural shingles.

OSHA also mandates that scaffolds be designed by a qualified person who has training in scaffold design, setup, dismantling and use and the scaffolds be constructed and loaded in accordance with that design.

Also, scaffolds may not be erected, used, altered or moved so any component of the scaffold or conductive material on it comes within 10 feet of uninsulated, electrical power lines. Your employees should treat all overhead power lines as uninsulated because the protective material on many power lines cannot be relied on to prevent electrical current from contacting conductive scaffold components, other materials or workers.

Ladder use on scaffolds is a common focus of OSHA compliance efforts. Ladders may be used on large-area scaffolds (of which ladder jack or pump jack scaffolds are likely not included) to increase the working height only when the following conditions are met:

• The scaffold is secured against the thrust force created by ladder use when the ladder is placed against a structure that is not part of the scaffold.
• The scaffold platforms on which the ladder rests are secured against movement.
• Both legs of the ladder are on the same platform or the ladder is stabilized to protect against uneven deflection of the platforms.
• The ladder legs are secured to prevent them from slipping or being pushed off the platform.

The fall-protection requirement for scaffolds differs from the fall-protection threshold of 6 feet specified in Subpart M of OSHA's general construction provisions. Workers on scaffolds more than 10 feet above a lower level must be protected by guardrails or personal fall-arrest systems.

Many roofing contractors are unaware that OSHA prohibits the use of ladder jack scaffolds when platform height exceeds 20 feet. Additionally, ladder jack platforms may not be bridged from one set to another.

In some instances, OSHA requires specific design provisions in scaffold applications. Tube and coupler scaffolds more than 125 feet in height must be designed by a registered professional engineer and constructed and loaded in accordance with that design.

An important issue

Although roofing contractors often delegate elaborate scaffold setups to specialty subcontractors, scaffolds should be an area in which you are well-versed. Avoid penalties by becoming familiar with OSHA's regulations regarding scaffolds.

Harry Dietz is NRCA's director of risk management.