Loss Control Insights for Contractors
Rental Scaffolding Inspections: Whose Job Is It?
For contractors insured by EMC, falls from elevation are the most costly accidents, averaging over $48,000 per claim. If you examine the data, this category includes falls from a variety of elevated surfaces including ladders and roofs. Many of the incidents involve falls from scaffolding.
These days, very few tradespeople own their own outdoor scaffolding systems. It’s much easier and more efficient to work with a scaffold rental company who handles set-up, take-down, transportation of the system and maintenance of the scaffold components between jobs. This reliance on rental companies for scaffolding, along with customer perceptions that rental companies are “full service” operations, has led to some misconceptions about scaffold safety and who is responsible for maintaining it.
Working at Heights – High Stakes for Employees and Employers
Falls from elevation are a big deal. In the construction industry, falls from elevation (as opposed to falls on the same-level that occur when you trip over a cord or slip on ice) are responsible for 1/3 of all worker deaths. That means that of all the hazards you deal with every day, a fall from elevation is the thing that is most likely to kill one of your employees. So doing everything we can to prevent falls is important. And if that statistic isn’t enough motivation for you to make scaffold safety a priority, consider this: scaffolds are a magnet for OSHA. That’s because they’re easy to see from a distance and just a glance can tell a compliance officer whether you’re getting the obvious stuff (like guardrails and toe boards) right. They’re an easy target, so you want to make sure you’re on top of scaffold safety.
Choosing a Reputable Rental Company
The first step to safe scaffolds is working with a reputable rental company that understands the rules and help you comply. How can you know if a specific company is on the up-and-up? Based on your experience in the industry, you probably already have an idea of the reputation of a prospective rental firm. Beyond that, there are a few quick indicators that can tell you if the company understands scaffold safety or not.
Red Flag #1: If the rental company’s delivery truck shows up with a load of scaffolding parts, but you don’t see an access ladder anywhere, that might be an indication that the company cuts corners and isn’t going to live up to the requirements set out by the OSHA standard. How are your employees supposed to safely enter the scaffolding without an access ladder? The simple answer: they can’t.
Red Flag #2: If you ask the rental company rep, “What are my inspection requirements?” and he or she looks like a deer in the headlights, that’s an indication that they may not be well-versed in the requirements in the first place, and will therefore have a hard time helping you comply with them. On the other hand, if the rep is able to explain your role in scaffold inspections that’s a good sign. Bonus points if they already have an inspection checklist available for your use.
Be Safe From the Start
Most companies that rent scaffolding do a pretty good job setting it up, but it’s still your responsibility to check the work they’ve done and make sure it’s safe for your employees before it is put into use. Observe the set up process to make sure everything looks right. Most importantly, you want to make sure the ground conditions and the base of the scaffolding are solid.
If your rental company is one of the good ones, they are not only looking out for the safety of your employees during the set-up process, but they’re also taking action to keep their own employees safe. This means the workers are using fall protection whenever possible as they build the structure. This is a benefit to you as well, because a lack of safe work practices on their part could impact you if an injury occurs and it’s determined that you were the controlling employer in a multi-employer worksite.
Your Inspection Responsibilities
There’s a big misconception when it comes to ensuring scaffold safety on the jobsite. Many people are under the impression that the scaffold rental company’s initial inspection and certification means the system can be considered safe throughout the duration of the project until that same company returns to dismantle the scaffolding and haul it away. This is not so.
After the initial setup, the responsibility for making sure it’s safe to be used lies with you. Scaffolds should be inspected by a competent person after being built, before being used and periodically during use (depending on weather, how much use it receives, how often it is modified, etc.). A competent person should also inspect the scaffold before each shift and after any event that could undermine its structural integrity (something like a rainstorm).
Defining a Competent Person
According to OSHA, a “competent person” is one who:
- Is trained to understand the requirements of the scaffold standard
- Can identify scaffold hazards
- Has authority to immediately correct and eliminate hazards
People can become “competent” by virtue of training or experience or both. It’s a good idea for you to document who is considered competent for scaffold inspections. You can choose to identify them by name, but it’s usually better (and requires less upkeep) if you can identify an entire class of employees as competent (for example, “all foremen” or “all superintendents”). Record your competent people or classes in the scaffold section of your safety manual.
A competent person doesn’t necessarily have to be on-site babysitting the scaffolding at all times, however they do need to be there frequently enough to make sure it’s still safe under changing conditions at the worksite.
Technically, OSHA does not require that scaffolding inspections be recorded. However, if you aren’t keeping a record of them, how can you prove that you actually did them? Documenting inspections is a good way to be prepared in the event of an OSHA inspection, but more important than that it’s a way to help hold your employees accountable for taking the actions that will keep their fellow workers safe.
This kind of record keeping doesn’t have to be complex. Tagging systems are convenient and functional, and may be offered by your rental company. With this method, a tag is hung at the entrance to the scaffold. A green tag means the scaffold is safe to use, yellow means it’s being worked on and red means it’s not safe for use. The tag is a quick and easy visual signal that tells workers the status of the scaffold. There are also spaces for the competent person to check off and date, so it’s a great way to document that you’re complying with the standard.
Find More Online
- OSHA’s Scaffolding eTool — includes illustrated checklists and requirements organized by scaffold type
- StopConstructionFalls.com — features toolbox talks, handouts and spot the hazard activities
- A Guide to Scaffold Use in the Construction Industry
- Working at Heights Resources from EMC Insurance
- OSHA’s Fall Prevention Campaign