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February 18, 2013
Fall protection: Do your COSP and IIPP include scaffolds? What to cover

Scaffolds enable workers to perform work at elevation more safely than ladders or some other types of equipment, but like many useful pieces of equipment, they can also pose a hazard to workers. Scaffolds may collapse while being erected or dismantled, or if they are incorrectly assembled or overloaded. Workers who don't know the risks can fall.

If you use scaffolds of any type in your workplace, you are required to include them in your Code of Safe Practices (COSP) and your Injury and Illness Prevention Program (IIPP). These are the first two documents a Cal/OSHA inspector will ask to see, so be sure they are complete.

Each document must cover specific aspects of scaffold safety.

Practice tip

Besides the general information requirements, your IIPP and COSP must address any hazards specific to the scaffold(s) you are using.

The COSP

Workers are covered by the Construction Safety Orders (CSO) if they are employed in construction, alteration, painting, repairing, construction maintenance, renovation, removal, or wrecking of any fixed structure or its parts. CSO Section 1527(b) requires all construction workplaces to create a COSP and keep a copy at the worksite.

Cal/OSHA specifies some of the language that must be included in a COSP, but other topics must be included as needed, including scaffolds.

Your COSP must cover the following aspects of scaffold safety:

Scaffold erection and dismantling. The following general requirements apply to scaffold erection and dismantling and must be covered in your COSP:

  • Scaffold erection and dismantling must be supervised by a qualified person.

  • Scaffolds must be built from the bottom up, and dismantled from the top down. When scaffolds are dismantled, structural members must not be removed below the level being dismantled.

  • Scaffolds must be erected and dismantled according to design standards, engineered specifications, or manufacturer's instructions.

  • Scaffolds must be secured to the structure during erection and dismantling. Ties to the structure should be installed as soon as the scaffold is completed to each tie-in area. During dismantling, ties must be removed only as the work progresses downward—unless other methods are used to prevent the scaffold from falling over.

  • Scaffolds that will exceed three stories or 36 feet in height must have a Cal/OSHA permit.

  • Scaffold erectors and dismantlers, as well as other employees working nearby, must wear hard hats.

  • Footings must be sound and rigid, and the scaffold and each level must be maintained plumb.

  • If platforms are sloped, the slope must be no more than 2 feet vertical to 10 feet horizontal.

  • Platforms must be secured so they can't slip.

  • When a platform turns a corner, the planks must be laid to avoid tipping.

  • You must provide proper access, guardrails on open sides, and toeboards on all railed sides.

  • Electrical safety clearance distances must be maintained, and long materials like gutters and pipes must also be considered when determining clearances.

  • Scaffold requirements may vary by trade; each trade should be aware of its particular requirement.

Scaffold use. Scaffolds should only be used as recommended by the manufacturer, and only by workers trained in scaffold safety, including scaffold inspection and hazard correction.

Basic precautions for safe scaffold use include:

  • Do not overload scaffolds.

  • Use only the safe means of access. Do not climb railings.

  • Climb safely using both hands, and face the rungs as you climb up or down.

  • Do not work on slippery rungs or platforms.

  • Do not extend working heights by, for example, standing on a bucket or rail.

  • Do not remove any component of a completed scaffold—such as a guardrail—except under a qualified person's supervision.

The IIPP

All California employers must create an IIPP to address their workplace hazards. When your workplace includes scaffolds, your IIPP must cover:

Scaffold inspection and hazard correction. Scaffolds should be inspected daily and before each use, and hazards should be corrected as soon as discovered. Hazards requiring correction include:

  • Missing or damaged planks

  • Missing guardrails or toeboards

  • Missing or improperly supported base plates, or legs and platforms that are not plumb

  • Braces, runners, or cross-bracing that are missing or not secure

  • Broken pins on frames

  • Scaffolds not properly tied to the building

  • Proper access

  • Clearance from electric lines

  • Overhead obstructions

  • Platform slopes that exceed the maximum allowable slope

  • Planks that are over- or under-extended, or that are substandard

  • Platforms that are not fully planked

  • Overloaded scaffolding

  • Slippery platforms

Training for scaffold users, erectors, and dismantlers. Because many types of scaffolds are available, workers need to be aware of the risks associated with the particular scaffold they will use. Train scaffold users, erectors, and dismantlers on all aspects of safety, including:

  • All potential hazards (structural, fall, falling objects, electrical, and other possible hazards), and

  • Maximum intended load and capacity.
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