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Safety Fierce

Paul Deffenbaugh

Does the January cover of MCN show an OSHA violation? Many of our readers say, "Yes." In fact, a lot of you say it shows multiple violations. I heard from you by email, phone and through our website, and for the most part you expressed concern that we would be encouraging unsafe behavior on jobsites because of this depiction.

If I know anything from editing construction magazines for, oh these many years, it's this. If we put a picture on the cover that shows an OSHA violation, we will hear from our audience immediately and vociferously. I love that people in this industry are so fierce about safety, and we want to encourage that as well.

I read the image differently, and didn't think were showing anything unsafe. Still, I'm an editor, not a safety expert, so I turned to Dean McKenzie, the Deputy Director for the Directorate of Construction at OSHA. I asked McKenzie to address four specific issues our readers had raised about the image.

January 2015 CoverPossible OSHA violations

Before we go into this, a note. The cover image is a cropped version of the image that appears inside the magazine. I asked McKenzie to make his determinations based on the complete image, not the cropped version.

Here is a list of the infractions our readers have identified:

  • No fall protection for the worker
  • No toe kick to keep items from falling off
  • No sleeves on the worker's shirt
  • No cross bracing

Fall Protection: McKenzie says, "It appears because of the way the photo is, that is looks to me that the scaffold is two frames high. In a narrow gauge or baker scaffold like that, the frames are typically five-foot tall frames. Two frames plus casters would put him over 10 feet and fall protection would be required. 10 feet is the trigger height for fall protection on a scaffold."

Some readers commented that six feet is the trigger height. McKenzie says scaffolding falls under subpart L, and ten feet is the trigger height.

The best fall protection would probably be handrails, which the manufacturer can supply. For more information on scaffolding requirements, you can download the OSHA PDF on narrow frame scaffolding at www.osha.gov/Publications/OSHA3722.pdf. For the general requirements on scaffolding contained in standard 1926.451 go to www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10752

Toe Kick: We can't determine if there are any workers below the scaffolding, but the requirement for toe kicks kicks in if the "scaffolding plank is more than 10 feet or there is a hazard of of things being kicked off the scaffold to workers below," says McKenzie. "We can't see anybody below, so we can't answer it because I don't have enough information. But I understand why it's suspect."

Sleeveless Shirt: There is no requirement in OSHA, says McKenzie, "that thall shalt wear a long-sleeved shirt." He points to the personal protective equipment requirements and specifically to standard 1926.95 that says where there is a hazard an employee must be protected. "A metal stud has sharp edges. The screws and all that are sharp. He is probably in violation there to not have sleeves." For more information on the OSHA standard 1926.95, go to www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10658

Cross Bracing: "The little angles under the planking qualify as cross bracing," says McKenzie. "It is engineered that those are the bracing. But we don't know how tall that scaffolding is in this image. There might be another deck plank that would tie it together. You can't go over two sections without more bracing. They are manufacturer's recommendation, and we would require you to follow manufacturer's recommendations."

A Comment about Evaluating Images

As you can tell, McKenzie hedges his bets a bit about the image because of the lack of information. "One of the hardest things we do here at OSHA is publish a photo. We've got a bazillion photos of people doing it wrong. But the guidance photo and the training photo for the guy doing it right, is really hard for us to come by. Have to send a picture through ten levels of review. And everybody is picking it apart. Does he have his glasses on? Is the guy in the background wearing his gear right? Right on down the line."

McKenzie and I have a slight disagreement about how to read the height of the scaffolding. He says, "On this particular image, with the portalet on the side, if you follow the slots in the middle stud, which are just above that align with the deck that he is standing on, so it's got to be at the 9 to 10 foot range."

I read it by looking at the joist lying on top of the scaffolding. It runs parallel to the installed joists and cuts across the portalet well below the top. That said I don't have enough information to assert that the worker is standing below 10 feet. We can't see the floor, and the portalet may be up on a platform.

According to McKenzie, on the fall protection issue, there is not enough evidence in the image to issue a citation. He adds, "If I saw this image, I would be happy to go look. It does draw the question."

Conclusion

I think McKenzie says it best. "The photo looks suspect." There may be no violation here (with the exception of the sleeveless shirt) but it sure does look like there is a violation-or multiple violations.

For that reason alone, we should not have selected this image for the cover, especially the way it was cropped. I would also suggest, we should not have used it in the article as well.

We are thrilled, though, that are readers are so focused on safety that they take time to call us to task for not taking it seriously enough. The most important thing in all of this discussion is that the people doing the work on our sites, often in difficult or dangerous circumstances, get to go home to their families at the end of the day.

What violations do you see?

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