The Ideal Construction Safety Manager

The role of a safety manager in the construction industry is both a challenging and rewarding position. The demands of the position are enormous and varied and the safety manager is never going to get much recognition for the work they do or any credit. It is hard to quantify the issues that were prevented and the lives saved - a tree that never falls in the forest doesn’t make a sound after all.  Some describe the job as 24/7 putting out fires and though that can happen when one gets reactive versus proactive, the best safety managers do their best to stay ahead of things and make sure there are no fires to put out. When people contact safety managers, it usually isn’t to share good news, but because there is a problem, so a big part of the position is problem solving and dealing with issues. Another aspect of being a safety professional is that for many of our customers it is a position which is seen as adversarial to production and is not highly respected. The safety managers are put into conflict constantly and have to deal with difficult people all the time, often trying to convince people to do things that they didn’t want to do in the first place. Yes, some people in safety are highly respected and valued in the professional but unfortunately for each one of them, there are many people who are not.  Part of this negative perception comes from companies who lack the appropriate culture and don’t value safety in the first place and thus make short-sighted decisions. As an example, these types of companies often place injured workers or problem employees into the safety position with little forethought and unfortunately this often does a disservice to the profession. The other part of the negative perception is some of us do it to ourselves in our approach, our lack of experience/knowledge or in how we do business.

I always find the perceptions about safety professionals interesting. You have an individual who often has a degree or if not, has more training, credentials and certifications than most other field-based people on the project. Safety managers need to understand all the various rules, regulations etc. and be able to apply that to all scopes of work, so thus they also need to be well educated and experienced in all the trade and subtrade processes, means and methods. The role is highly technical and the manager needs to be able to communicate that detail to people from many different walks of life in a way that they can easily understand. The role also impacts the bottom line directly and indirectly in vast ways and thus the safety position often can be a huge profit center. Safety managers also serve as a bridge between the craft workers, field supervisors, project management, executive management, client reps and third-party inspectors.  Good safety pros have a pulse on the field and culture of the project and can be powerful leaders and liaisons between all parties. Truly this is a unique and challenging role for which only people of special abilities excel. So what makes a good safety manager?  I think that answer depends a lot on the specific role and needs of a company/project, the culture of that company etc. but in having interviewed, managed, worked with and interacted with many safety professionals in my career, I can definitely share some of the characteristics of those who do well in the role and those who do not. Here is what I look for when I am trying to find top class safety managers.

1.       Strong Technical Skills

First things first, a good safety professional needs to know their business.  If they don’t have a firm grasp of the hazards, risks and various safety rules that apply to the scope of work they are overseeing they are going to struggle and people who know their business will know instantly whether the safety manager knows what they are talking about or not. Nobody expects anyone to be able to cite section numbers and recite the code word for word, but one should know enough to have a pretty clear idea what is what and know where to look up the answers. Related to this, one pitfall I see many safety professionals take is that they feel the need to be the authority. Having the humility to say, “I think it is this, but I will double check and get back to you” is certainly better than opening our mouths and saying something that is not accurate which can quickly erode trust and respect. 

Getting the technical skills and knowledge is best obtained through training, studying the code and perhaps most valuably, hands on-experience working in and around these activities. The ideal safety manager embraces continued education, is always learning and building on their skills.   

2.       Credentials

Related to technical skills, credentials have their place in the profession.  This is not an endorsement of any specific credential but for commercial construction, the BCSP has done a great job of marketing their credentials to the point where these are now seen as minimum requirements by many construction employers and clients. I don’t think having a CSP or CHST instantly makes anyone smarter than they were before they had it and rather to me it is more a validation of the knowledge one already has but the process of studying for and taking the credentialing exam does provide learning opportunities, refreshes some information and rounds out the safety professional in those areas that may not always be utilized in daily practice. We all know someone who has a credential or degree in safety who couldn’t manage themselves out of a wet paper bag. No amount of credentials can replace experience, competence and common sense. This all said, more and more, rightly or wrongly, credentials are now part of the profession and open a lot of doors. There is a lot to be said about someone who recognizes where the industry is going and has done the work to apply, take and pass the test and keep that credential versus someone who has not. To me, that level of conscientiousness is admirable and the dedication and willingness to get the credential done speaks volumes about their drive and commitment to what they do. Not everyone is great at test taking but there are so many tools out there now to assist in the process, that there are few excuses anymore. Again, not everyone who has a credential is a solid safety manager, but on the flip side, the unwillingness to seek a credential shows that an individual is resistant to change, to self-growth and to betterment and personally I prefer working with people who are motivated to improve, better themselves and also shows they are committed to keeping up with the industry happenings.   

3.       Good Approach

How a safety manager interacts with the people they need to connect with on a daily basis is one of those soft skills that is vital. Nobody wants a safety cop, someone who is unreasonable or has zero communication skills. Nobody wants a person that is a talker, is ineffectual or is too friendly with everyone either. Finding that balance of friendly and kind versus professional, assertive and firm is a talent. Good safety managers have done the advance work to get to know people, form relationships, know their names etc. This goes a long way in becoming relatable, trusted, valued etc. Do they say hello, engage in small talk before they talk to them about a safety issue or do they just dive in and tell them what they are doing wrong or what they need to do?  “Seagull safety” is not the approach we want to see – namely swooping in, squawking, pooping all over things and then flying away leaving a mess behind. The ideal approach is one where the person is treated with respect, talked to, coached, where the manager tries to help, tries to find common ground etc. Be respectful, be empathetic, don’t condescend, no yelling, no power trips etc. Asking questions about what the worker is doing, why they are doing it the way they are, how they could maybe do it better? Be a good listener. Having the humility to ask questions, learn and fully understand before one makes any judgments is a good skill. We will also learn a lot and further, that approach appeals to the other person’s expertise and knowledge which in general people appreciate. Everyone is trying to do a job, nobody wants to get hurt etc. We all have different ways of going about it and though some are knowingly cutting corners or playing games and should be dealt with accordingly, for the vast majority there are better ways to get people to do things than coming on strong, exerting authority etc.  It is hard to gain respect, trust etc. this way and without trust and respect one cannot be as effective. 

4.       Personable

A good safety manager is a good communicator, personable and makes the effort to get to know people. If they are pleasant to be around, positive, are interested in others, show some of their personality (but keep the crazy stuff under wraps) and make themselves available to others, people will be attracted to them and go to them when they have questions and the safety manager will be someone that is trusted, respected etc. Not everybody can be a people person but those who are often make great safety managers. One of my former supervisors said that to be an effective safety manager on a project you needed to know everybody’s name, their children’s names, what they do etc.  I believe he overstated things a bit but the overall message is on target. Safety managers don’t need to know people so well that they were having them over for Thanksgiving dinner necessarily, but well enough to be able to relate, understand who they are, what they are about, their interests, what motivates them etc. They have done the work of building relationships, finding common ground and establishing trust. Building relationships is part of the job and actually one of the more enjoyable aspects of the work in my opinion. There is a fine line between communication, talking about personal things, getting to know people as part of the job and just talking to people and not doing the job or taking people away from doing their job. The good safety manager should never be the person that never seems to be doing anything other than talking about their fantasy league picks, what they did last weekend etc. Good safety managers can relate and connect in a way that they are not being a distraction, a nuisance and impacting production. It is also not about making sure everyone likes the safety manager either – it is not a popularity contest and not everyone is going to like the safety manager. Everyone should however feel like the safety manager is approachable, trustworthy etc.   

In being personable, be careful to make sure we are not excluding anyone – I know some safety pros who neglect the office and don’t build those relationships with the execs, PM, superintendents etc. because they feel the need to be in the field 100% of the time. They miss out on a huge part of their support network. I also know safety pros who spend too much time in the office and not enough in the field. I always found a good balance was about 80% field – 20% office though that depends a bit on the needs of the project. 

The last bit about being personable and forming relationships, is that some people become very close with folks, so much so that they do things together outside of work. It is great to form those connections around shared interests, I would just caution to be careful about maintaining the professional boundaries.  It can get difficult when hard choices need to be made with close friends or when others feel there is favoritism. Some can walk that line seamlessly and others struggle with establishing those boundaries.

5.       Have a Strong Network

Related to being personable and communicating, an effective and strong safety manager should know the safety manager/lead supervisor for every trade on the project. They should invite them to the project, walk with them, get to know them, go to lunch or whatever it takes to build those networks especially when all is going well. Those relationships and that network is vital as the safety pro moves through their career and provides a great asset to getting things done and being effective on a project. These connections are also valuable trade specific resources and we can never know it all. Construction is a small world, people move around a lot and connections are vital. Safety professionals who have this network are often team players, personable, trusted, respected, etc.  It also shows their mindset and maturity in their overall approach to the foreseeable challenges in the future.

6.       Demonstrate Real Concern for People

How one communicates what they are trying to do and the reasons why matters. People are drawn to and trust those who demonstrate that they truly care for them and their wellbeing. If we come from a place of caring and respect versus one where we are writing people up, snapping photos and posting them on the wall of shame, etc. matters. If it is all about compliance, command and control and that the safety manager clearly doesn’t care who the person is as an individual or if they work on the job or not, this is readily seen. The ideal safety manager never takes things personally. Saying something like: “Look, I am trying to help you out here. I am not here to get up in your business, tell you how to work or do anything – you are free to do what you want. However, this project has certain requirements and if you continue doing what you are doing, it will impact your ability to continue to work here and in my experience may even impact your life and health. I have seen a lot of things in my time from people doing what you are doing and I don’t want to see that happen to you okay. I want you to finish this project in the same shape you came into it or better and leave proud of a job well done and with a little money in your pocket” is received a lot differently than “Put on your (insert your favorite curse word here) safety glasses or I am sending you home.” Intent matters and the best safety managers come from a place of caring, compassion and respect.

7.       Dependability

The ideal safety professional shows up for work on time or even better ahead of time, every day, always.  As the saying goes: “early is on-time, on-time is late, and late is unacceptable.” Safety managers need to be reliable and someone the team can count on to be at their post and taking care of business. For many safety professionals we are some of the first people on the project and are getting people through screening, completing orientations, reviewing JHA’s / Pretask Plans, completing morning huddles, getting permits signed, inspections done etc. Our teams are relying on us so everyone else can start their day efficiently, safely and on time. Nobody likes excuses or drama and everyone on the project has enough things to deal with that they don’t need to manage a staff member who can’t seem to get to work on time or at all, is hungover, not engaged, lacks a spark etc. If the safety manager’s personal life is getting in the way of their professional life, they need to fix the personal life. Stuff happens from time to time for everyone but if I see various personal issues consistently impacting work life I think very hard about working with that individual and usually don’t. If people can’t manage their personal lives in such a way that all this drama doesn’t spill over into work, then I can’t expect them to manage their work lives any better especially with all these distractions. I do understand that life is complex and things happen, including big issues (e.g. divorce, illness, death etc.) and provided these types of things are the exception, versus the norm, we can usually work around things. It usually comes down to communication, professionalism, a strong history of good performance and trust. Good workers and safety leaders are professional, conscientious in all they do and should set the example. Ideally, there should be no drama and the only things people should associate with a safety professional is their solid body of work.  

8.       Handles Escalation Well

One could write a complete article on proper escalation methods and it is beyond the scope of this discussion but I will summarize things by saying that this is perhaps one of the more common ways that safety managers get themselves into trouble. Some basics about escalation include measured responses, following the chain of command, overcommunicating, solid documentation, having the necessary backup/support, eliminating he said/she said scenarios etc. Staying calm and level-headed throughout and always keeping cool are crucial as well. Just like in sports, they always catch the person who retaliates and I can count many examples where the safety manager was provoked, targeted, assaulted (verbally or even physically) and because they reacted, they were removed from the project or otherwise disciplined and often the other party got a slap on the wrist or nothing at all. As a safety professional, we know better and again, we have to set the example. Though it is extremely hard sometimes, we have to stay professional at all times and stay above the fray.

Though we often have the authority to remove people from the project or implement disciplinary action, my preference is to have the safety professional removed entirely from the disciplinary process if possible. I see our role as to coach, support, advise, report etc. If we become the judge and executioner we are not as approachable, trusted etc. and again, it often doesn’t go well for us. We don’t hire the workers, dispatch them, give their reviews, decide on their bonuses, pay them etc. and I don’t feel we should be directly involved in terminating or removing anyone from projects. The only exception is if we have safety staff who are direct reports which of course we should be involved with. That exception aside, I see the role as making strong recommendations, helping facilitate the review process, providing decision makers with the information they need to make decisions etc. The direct supervisor should make the final call on what to do with their employee. Whatever that supervisor decides we need to be okay with and we cannot get too personally indebted into the end result. If we did our job and provided our teams with all the information they needed, usually management makes good decisions, but not always. Sometimes these decisions provide an opportunity to privately coach those supervisors after. I know many a safety professional who had a chip on their shoulder, ego, needed to show they had the authority etc. who got too personally indebted into these types of decisions and couldn’t let go. I have also seen safety pros who perhaps jumped the gun or in the heat of the moment tried to remove someone from the project only to get their legs cut out from underneath them and the person they were trying to remove not only became emboldened but remained on the project and undermined the safety manager at every turn. These types of things usually go poorly for the safety manager. Control, needing to be right and power plays are not leadership. When safety pros start removing people, disciplining, impacting livelihoods, impacting production etc. is where many problems start. The best ones maintain their poise, stay level-headed, keep themselves out of the mud and guide the worker’s direct supervisors to deal with and discipline their employees appropriately.    

9.       Brings Value

The best safety professionals add value to the project. They do this in multiple ways. It could be something simple like rolling up their sleeves to pick up some trash, replacing rebar caps, and pitching in to help wherever they can to truly helping people out and going the extra mile to assist a subcontractor with some paperwork, training or some task - all of it helps. Superintendents on projects have enough fires to put out and problems of their own they need to solve and it is our job to help support them and the project by dealing with things, solving problems etc. The last thing they need is a giant list of more problems. Take care of things, be proactive, lend a hand etc. Safety managers need to be careful about wanting to help so much that they feel their job is to make sure nothing makes it to the superintendent’s desk. That is a bear trap. When big things happen and escalate and they will from time to time, we will have wanted to make sure we have communicated everything to the team and that everyone who needs to be in the loop is. The ideal safety pro makes sure they are communicating what they are doing and understands what level and how much communication each member of the team needs/wants. Safety professionals can help or they can take on so much that they actually hinder. There is a difference between helping and enabling, but sometimes for the sake of the job schedule, a safety manager may need to be more involved to make things go smoother, particularly on those time sensitive items. Safety managers who can integrate themselves into the flow, keep things safe and keep production going are more highly valued. Those who are stopping work all the time to talk about things, hold a few meetings, exert their authority etc. aren’t as valued or usually well-liked either. Work stoppages are needed from time to time and we should never compromise on safety but it shouldn’t be the go to tactic for everything or even most things. Mostly I see those as power plays and the safety manager can often deal with things more efficiently. We can’t fix 30 years of poor ingrained safety behavior overnight but we can certainly solve the immediate issues while focusing on the long game too.  It can be frustrating and thankless work, but it all helps.

10.   Can Find the Grey

As any seasoned safety professional would attest to, safety is criteria dependent and thus safety determinations depend on a variety of factors.  Things are not always black and white and oftentimes the required safety protocols or OSHA regulations that are there to guide us cannot feasibly or practicably address the necessary work tasks or demands.  In these situations, finding the grey and coming up with a solid and safe work plan is vital. Good safety professionals can anticipate these issues and can often get ahead of them. They know how to negotiate these grey areas and help workers develop a plan to get the work done given the unique circumstances present without compromising safety. Sometimes, these plans are not 100% technically compliant but they do provide an equal and effective means to address the risk. To be clear, I am not advocating that safety professionals ignore the regulations and for some projects/clients absolute and strict compliance with the letter of the law is vital, but rather I am acknowledging the reality that things come up that were not planned, reasonably anticipated etc. for which strict adherence to the regulations would be extremely impactful if not infeasible or impractical. It is for those situations that I am talking about. Many safety managers early in their career only see things as black and white or fail to anticipate or understand the situation/problem. Nothing degrades a relationship more quickly than being seen as unreasonable, not willing to listen or difficult to work with.

11.   Confident

Good safety professionals are not shy. If they see something they should feel comfortable speaking up and saying something. If someone is afraid to talk to someone or say something that is not an effective manager. A good safety manager should have a bit of swagger and confidence - not so confident that they think they know everything or come off as arrogant, but rather the confidence of knowing their business, the scope of work and the rules that come with it. Safety managers should know more about safety, risks, controls than anyone on the project and thus should feel comfortable and confident in addressing anything that comes up. Confidence does not equal arrogance. Confidence is believing in one’s self and abilities, arrogance is thinking they are better than others and acting accordingly. The safety pro should never be arrogant.

12.   Disciplined

The ideal safety manager is disciplined. A safety manager can never compromise on safety and always needs to set the right example. They can’t take shortcuts on the job, always need to wear the right PPE, and ensure all the rules are followed at all times. If the safety professional cuts a corner they lose some of their integrity. Similarly, if the safety manager sees something they can’t just walk by and say nothing either.  These are great ways to lose respect and trust. 

Related to discipline, is consistency. Good safety managers apply the rules consistently to all and not being consistent can quickly destroy one’s credibility. As a leader, we don’t want to ever do anything that will lose the respect of the team. Making up things, applying double standards etc. can quickly undermine the safety manager’s efforts. If we don’t know the answer to something, admit we don’t know and then look it up. Trying to be the person with all the answers all the time will eventually catch the safety manager in a bear trap and it is okay to admit (and we should admit) when we are wrong when it happens. 

13.   Responsive

Good safety managers are responsive.  If someone shares a safety concern we need to act on it. That action could be obvious or if it is less obvious we should follow-up with the person and let them know what we did, that we appreciate their concerns etc. If the safety professional is seen as someone who doesn’t do anything or responds to them, they will think they do not care and will stop reaching out to them. Responses need to be timely, targeted and we should thank the person who brought their concerns to us. Safety is sometimes used as a stick to gain leverage or retaliate between trades on a project, but in my experience most of those items that are brought up in these sorts of games are usually valid safety items, so we need to respond to them. I also find that the person using safety as a stick often has plenty of their own issues to address and these are good opportunities to help them clean up their own house if they want to maintain at least some of their dignity and self-respect.    

14.   Conscientious

Conscientiousness is doing one’s work to the best of our ability, all the time, being thorough etc. It takes effort, focus and requires consistency and patience. Most initiatives and changes don’t happen overnight so we need to be patient and persistent to see them through and see the impact. I want safety managers who are diligent, focused, conscientious etc. in their work, in their relationships, in their documentation and even in their appearance. We are professionals and we should not have sloppy reports with spelling errors and grammatical issues throughout. We should look professional as well and untucked, wrinkled and dirty clothes don’t send the right message either. Appearances matter and if we act, work, speak and look like a professional at all times, we should be treated as one and gain the trust and respect of our teams. If we are making the effort, day in and day out, that also shows and in doing so, we bring value and will achieve results. Nobody likes someone who isn’t pulling their weight or does not uphold the values of the project/company. Those people are a low-grade infection to the culture of the company/project in my opinion. 

15.   Humble

I always appreciate the safety manager who has humility. The ones who admit they don’t know everything, who will ask questions, seek answers from others, get the whole team involved and are open to suggestions from others are far more effective and less dangerous than those who think they know everything, think everyone else is stupid and act like they have all the answers already. The humble safety professional is often also the same one who will step up and take responsibility if they make a mistake, are wrong etc. It is okay to not be perfect, to admit we don’t know everything, to ask for help etc. – it is actually admirable - just don’t make making mistakes a habit or make the same mistake twice. The safety manager who acts like they are the know all/be all of safety on the site is not someone who inspires people. People don’t respond as favorably to arrogance, if they know someone won’t listen to them or act on their suggestions, talks poorly about others etc.  

16.   Honesty and Integrity

I have a difficult time tolerating people who lie and are dishonest. As the saying goes, lying liars lie. If a person can lie about one thing, they often are lying about other things too. If I can’t trust what they say, then I can’t trust what they do. I can’t have people work with me that I can’t trust. Also, with lying often comes other sorts of deceitful and dishonest behaviors and I prefer to work with people who are honest, who value the truth, are people of high moral character, that have integrity etc. I have found that there is far less drama and issues when working with people who are honest, have integrity etc. 

Related, people who are negative, talk poorly about others and are overly critical of others are a red flag for me. Consistently speaking poorly of others is not only unprofessional and shows a lack of respect for others but how do I know that same person is not speaking poorly about me or my company to others. It also often shows a lack of personal responsibility or commitment to improving things. The ideal safety professional is conscientious in their image, is always positive, solution-oriented and works to create a positive work environment.  Positive people are more trusted, respected and more well-liked. 

Conclusion

That is the list. This is not a complete list but hopefully provides some insights into some of the things I look for in world class construction safety professionals. Worksites are dynamic places, with many activities going on and tons of things that need to be done at any given moment. The job is hard enough on its own but when you add in dealing with and trying to influence people, some of them who are having bad days or are difficult to deal with even on their good days, it can be infinitely harder. The ideal safety manager has a good combination of hard and soft skills that make them good employees, good teammates, good leaders and good people in general. Applying them in the framework of construction safety helps send people home safely each day and I for one am thankful to have had the opportunity to know many people who have taken on the challenge of being a safety professional and have been able to make these kinds of positive impacts each and every day. 

Are Scaffold End Frames Considered an Acceptable Means of Access?

Over the years I have had numerous conversations with various trade workers as it relates to suitable and safe access to their work platforms when working on fabricated frame metal scaffolds.  Usually these discussions are initiated after finding deficiencies and workers climbing around the scaffold like spider monkeys. 

Are the end frames a safe and legal means of access?  If not, when are they not?  The answers to these questions depend on several factors and it has been my experience that many workers and even some safety professionals often don’t have the answers.

There are a few places where we can find those answers.  The first place we can look are the Federal Safety and Health Regulations for Construction - Subpart L Scaffolds 1926.451(e).  That section deals with scaffold access.  

1926.451(e)(1)

When scaffold platforms are more than 2 feet (0.6 m) above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used. Crossbraces shall not be used as a means of access.

As we can see “integral prefabricated scaffold access” is listed as an acceptable and safe means, which means the built-in metal scaffold end frame ladders.  If we look at the specific requirements for integral prefabricated scaffold access frames 1926.451(e)(6) we find that there are some additional requirements for safe access. These include:

  • Be specifically designed and constructed for use as ladder rungs;

  • Have a rung length of at least 8 inches;

  • Be uniformly spaced within each frame section;

  • Be provided with rest platforms at 35-foot maximum vertical intervals on all supported scaffolds more than 35 feet high;

  • Have a maximum spacing between rungs of 16 3/4 inches; and

  • Non-uniform rung spacing caused by joining end frames together is allowed, provided the resulting spacing does not exceed 16 3/4 inches.

The first item requires that these end frames be “specifically designed and constructed for use as ladder rungs”.  Do you know if your scaffold frame was designed specifically for use as a ladder or not?   What if the manufacturer calls your scaffold end frame a mason frame?  Does it need to be called a ladder frame?  Does it even matter what the manufacturer calls it?  These are some tricky questions which might be answered by reaching out to the manufacturer and their engineering department. In lieu of getting some sort of letter or response from the manufacturer which is often difficult we can examine the history of these scaffolds.  The original design for most end frames in common use today was done well before OSHA even existed, in the 1940’s, and those designs largely have not changed.  There are now basically 3 different frame design standards in the United States that dominate the market.  These include Safway Scaffolding type frames (Blue), Waco (Red), and BilJax (Yellow).

These three types dominate the industry and are similar in specs but do vary and should not be interchanged.  Most imitators have design specs that match one of these three.  The original mason frames were not designed with the intent of being used as an access point and the spacing of the horizontal bars on the end frames was mostly for ease of masonry installation and placing scaffold planks.   Blocks were generally 8” in height and stacked 2 blocks high with mortar worked out to an ideal spacing of 16 ¾ inches for the vertical bars but spacing varied generally between 16” and 20” and wasn’t always uniform. Walk through frames were designed to facilitate the use of a wheelbarrow for transporting mortar and block/brick.  When OSHA revised subpart L they consulted industry experts and arrived at a spacing of 16 ¾ inches for end frame ladder sections which included most designs currently in place.  As such, the majority of frames met the new standards and requirements for safe access.  Provided the frames met all the other requirements for access (e.g. rung length, spacing, uniform spacing etc.) they were considered designed and constructed for use as ladder rungs.   In a historical letter of interpretation related to the use of integral ladder scaffolds designed and manufactured from 1957 - 1987, Fed OSHA stated that the standard “should be liberally interpreted to permit the use of those ladder systems (both portable ladders and ladders built into the scaffold frame)”.  Therein it seems that OSHA was liberally construing that end frame ladder systems are designed and constructed for use as a ladder provided they meet the standard. If it looks like a proper access system it probably is.  Newer designs after the OSHA standard was established are presumed to also be designed and constructed for use as ladder rungs.

54“ Scaffold - Rungs Spanning Post to Post

Related to strength, in talking to engineers from some of the leading manufacturers, most scaffolds as typically used also meet the design standards.  A one inch rung is typically designed for a 250 pound worker and easily falls within the 4:1 safety factor.   1 ¼ inch or larger rungs are obviously stronger.  A worker that is 350-400 pounds will approach the 4:1 safety factor on a 1 inch rung on scaffolds with rungs that extend from pole to pole on a standard 5’ frame, which is a design that is less common. Most manufacturers that have rungs that span from pole to pole have shorter spans such as 2 or 3 feet or larger rung sizes. If the rung span is only half the span of the entire end frame (e.g. a ladder section with a walk through portion) those 1 inch rungs are more than adequate in strength. 

Obviously, we need to ensure the scaffold is designed for the intended use and an end frame scaffold with 1 inch bars that extend from pole to pole may not be suitably designed and constructed for the routine use of a worker who is 350-400 pounds.  In that same scenario we would of course also need to look at the scaffold in its entirety including platforms and their similar 4:1 strength requirements but that is a different conversation.  This all said, it is generally presumed that for typical use and set-up, that a standard scaffold end frame in use today meets the requirement to be specifically designed and constructed for use as a ladder rung. 

Rungs less than 8” in length

The second threshold to pass for safe access is that the rung length needs to be at least 8 inches in length.   This would exclude many types of walk-through end frames with rung lengths less than 8 inches as a safe means of access. 

Another requirement relates to uniform spacing within each frame section but allows there to be non-uniform spacing when joining end frames together.  Provided that spacing does not exceed 16 ¾ inches, those frames are also considered a safe means of access. The big three scaffold types are designed so that when properly stacked their spacing is uniform when joining end frames together.  One potential cause of non-uniform spacing for end frame ladders is mixing and matching end frames with different ladder spacings.

Some manufacturers provide “ladder frames” with spacing that exceeds 16 ¾ inches. This, to me, is misleading because even though those frames are called “ladder frames” those frames cannot and should not be used as a safe means of access.   

A Standard 5’ x 5’ “Ladder Frame” with 20” vertical spacing of rungs

It should be noted that for erection and dismantling, erectors/dismantlers are permitted to safely climb ladder rungs spaced up to 22 inches and non-uniform in spacing.  Once the scaffold is built and assuming the spacing is greater than 16 ¾ inches, those horizontal bars would not be considered a safe means of access for workers other than erectors/dismantlers engaged in erection and dismantling.  

Another criterion involves ensuring that the scaffold has rest platforms at 35-foot maximum vertical intervals on all supported scaffolds more than 35 feet high.  If there are no rest platforms on scaffolds greater than 35’ high, the integral ladders system is not considered a safe means of access.  Workers are not required to get off every 35 feet but they should have the ability to do so if they need to.  Many scaffold designers feel that it would be safer to build scaffolds in such a manner as to require that the vertical run is broken and forces workers to get off at rest platforms to transition to the next part of the ladder and those systems would require platforms on the exterior of the scaffold to most safely break up those ladder runs.   

The last item in the Federal standard relative to integral ladder systems states that steps and rungs of ladder and stairway type access shall line up vertically with each other between rest platforms.  What this means is that if a frame has a ladder side and a walk through side, that the ladder sides of the scaffold should all be oriented on the same side of the scaffold frame.   As you can see in the diagram below, in Figure A ladder sides of the frames are all oriented on the same side and thus stacked one on top of each other. In Figure B, the ladder sides of the frame switch from right to left to right.

Obviously if ladder frames were not oriented in a line vertically, it would create a hazard from someone climbing down and if they were not paying attention and didn’t see that the rungs below were on the other side (and did not continue directly below), they could place a foot into the open space of a walkthrough section, potentially falling or worse.  Similarly, the need to transition from side to side while climbing and descending introduces some further risk.  

If we are to look at the ANSI standards, they essentially mirror the Federal Standard.   ANSI A10.8 – 2019 Scaffold Safety Requirements states that “safe access shall be provided to work platforms of all types of scaffolds by one of the following” and then lists several types of safe access.   Item #2 in that list includes “scaffold frames designed for use as access and egress methods that are secured to support the eccentric load of workers climbing these components may be used when the maximum spacing between rungs of the frame does not exceed 16 ¾ inches.  The length of the rungs shall not be less than 8 inches.  There shall be sufficient clearance to provide a safe handhold and foot space.”

As Fed OSHA requires, ANSI includes that the frames must be designed for use as access/egress, maximum rung spacing does not exceed 16 ¾ inches and rung length of not less than 8 inches.  ANSI further specifies that the access method should be secured to support the eccentric load of workers climbing and that there be sufficient clearance to provide a safe handhold and foot space.   These additional standards would forbid, for example, an access ladder on the exterior frame of a small mobile scaffold that would tip if someone climbed up on the outside. Some safety professionals and even some OSHA engineers feel that an attachable ladder on a mobile tower is not desirable for this exact reason, unless the mobile tower has outriggers or some other means to stabilize it.  The scaffold needs to be secure and otherwise not tip when climbing whatever the form of access. 

The second part is sufficient clearance.  This basically means that the ladder rungs should have sufficient clear space behind them to allow a foot or hand to make sufficient purchase on the rung.  What exactly is “sufficient clear space”?  If we look at the Fed OSHA Construction Standards 1926.1053(a)(13) they provide some guidance relative to fixed ladders which is namely to maintain 7 inches clear from the centerline of the rung to the nearest obstruction in back of the ladder. 

California OSHA echoes many of these same requirements and can be found in Section 1637, Article 21 of the Construction Safety Orders.  Cal/OSHA requires a safe and unobstructed means of access is provided to all scaffold platforms and can be affixed or built into the scaffold by proper design and engineering.  As ANSI specifies, Cal/OSHA requires the access so located that the use of the access system does not disturb the stability of the scaffold.    Cal/OSHA’s rules are similar for rung spacing (max 16 ¾ inch), uniformly spaced, rest platforms at 35’ intervals etc. yet, requires rung length to be 11 ½ inches versus 8 inches.   Cal/OSHA has some specific rules relative to horizontal members of scaffold end frames used for access and requires them to be reasonably parallel and level, arranged to form a continuous ladder and to provide sufficient clearance to provide a good handhold and foot space.  Relative to the requirement for a continuous ladder, they reference section 1644 Metal Scaffold which states, “When only a part of the width of the metal scaffold frame conforms to ladder spacing, then these frames must be erected in a manner that makes a continuous ladder bottom to top, with ladder sides of the frames in a vertical line” which is consistent with the diagram above where ladder sides are all aligned on the same side.  I have heard arguments from plaintiff’s counsel in scaffold accident cases asserting that the gap in the center vertical rail created when connecting frames does not constitute a “continuous ladder” but “continuous” per my discussions with various Cal/OSHA engineers talks about ladder rungs, not vertical bars.  By this argument legal counsel is attempting to claim that basically all standard end frames in use are unsafe means of access because all have the “gap”, which is inconsistent with industry standard practice and use.   

The regulation talks about ladders sides of the frames needing to be in a vertical line and forming a continuous ladder bottom to top, not sides of the ladders in the frames – an important distinction.  It also ignores the first part of the sentence which states “when only a part of the width of the metal scaffold frame conforms to ladder spacing” and thus provides some context as to the meaning.  Again, Cal/OSHA staff has confirmed in conversations their interpretation of this section of the regulation, namely “continuous” refers to the horizontal rungs and ladder sides of the frames, not the center post or ladder rail.  The reality is workers are required to use the horizontal bars for purchase of hands and feet and unless someone had longer arms, requiring employees to use both vertical poles for their hands when climbing (versus the horizontal rungs) would require a spread of at least 2.5 feet for most standard frames and would make the scaffold awkward to climb for many people. It is far more efficient and safe to use the horizontal bars to climb versus the vertical posts. There are also no pins, crossbraces, locking devices, braces, couplers etc. that get in the way of hand placement on the horizontal rungs that would otherwise be present on the vertical posts. I am unaware of any scaffold in common use in North America that has an end frame that has a continuous center bar and thus there is always a gap present between frames.   Further, no manufacturer I am aware of makes an accessory piece that fills in that gap that is commercially available, so there is no missing piece either.  The “gap” is standard and safe.    

Last, I need to talk about shoring end frames.  These look like scaffold end frames and are often used for access but are distinctly different.  Most of these shoring sections were not designed and intended to be used as an access ladder (consult the manufacturer’s instructions) and many of them exceed the 16 ¾” spacing required and thus should not be used for access. 

I hope the following discussion has helped clarify when a scaffold end frame is considered a safe means of access and when it is not.  Not all scaffolds are designed or built the same and it is important to ensure the scaffold in use provides all workers a safe means of access to all work levels, whatever those safe means are. 

Scissor Lift Fall Protection - Required or Not?

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The need to have workers in body harnesses and personal fall protection (PFP) while operating a scissor lift has been and continues to be a point of healthy discussion and confusion for many. Well intentioned and knowledgeable safety professionals can and do disagree on this topic and if those who are expert cannot come to a consensus we certainly cannot expect those in charge of operating the equipment or supervising and managing the work to fully understand the hazards and provide the best controls for the situation.

There are several discussion points in this debate.  On one side there are those that see a well maintained and complete guardrail system as fall protection and where falls are seen as largely an employee behavioral, management and training issue.  They believe that if workers keep their feet securely on the platform, gates closed, etc. there is no fall hazard.   Followers of this line of thinking point to the similarities in someone working on a work platform or mobile scaffold with a guardrail system and no similar requirement for personal fall restraint systems (PFRS) or personal fall arrest systems (PFAS).   They may also point out that OSHA and ANSI/SIA in a plain reading of the regulation or standard do not require PFP.   They may further point out that wearing fall protection increases the hazards associated with crush injuries via getting caught in the controls or increases the hazards associated with the fall – perhaps in toppling the lift, pendulum effects and discussions about slingshotting the worker into the ground if a lift topples, no ability to jump free etc. to give some examples.  Others discuss complexity/confusion for workers in using the right personal fall protection system (PFPS) and discussions about arrest versus restraint, length of lanyards, type of lanyards, ability to actually move in the basket and perform the work, location and type of anchor points etc.   Other arguments relate to complacency in having a harness and a false sense of security.   

On the other side of the discussion are those that see OSHA and ANSI/SIA as minimum requirements, outdated and not the most protective, with some pointing out the requirements of the General Duty Clause and enforcement action related.  Followers argue that in general more is better and issues involving falls and scissor lifts are best controlled through personal protective equipment (PPE) and tighter controls to not allow a worker to climb up out of the platform.  They similarly point to manufacturer guidelines and white pages, interpretations from OSHA, EM-385-1-1 and similar as support of their arguments that PFP is required.  Some believe that anyone operating over 6’ needs to be protected and that the only law we need be concerned with is the law of gravity. Isaac Newton would be proud.  Followers disagree as to the best means and methods for a fall protection system and whether a fixed lanyard and restraint system or a self-retracting lifeline and arrest system is best but regardless of the precise connection device or anchor, the controls outweigh any increased risk associated with the fall protection system itself.  Further, many argue against concerns associated toppling the lift, sling shot effects, crush injuries and jumping free and in general feel they are overstated, largely unsupported or extremely rare and thus insignificant. 

Having crudely defined the main talking points and issues, it is worthwhile examining some of these viewpoints.

The next Darwin Award winner is….

The next Darwin Award winner is….

Falls and Scissor Lifts

Historically falls involving scissor lifts are associated with three prime factors:  climbing outside the basket, climbing up off the platform to gain elevation and leaning outside the rails.   Workers are generally not falling through the rails or in the gap created by a gate chain that was not secured.  There have been some instances where workers fall through the gate, however these often involve circumstances where employees knowingly pin open the entire gate so there is a gap in the complete guardrail system.  It should also be noted, that new ANSI/SIA standards for design of lifts are doing away with the chain gate and going with a rigid, self-closing gate with toeboard system which should reduce issues with hanging chains etc. though still does not address a worker who knowingly wires the gate in the open position.  It will take a while for older lifts to cycle out and/or get refurbished but as it relates to unsecured chains and falls this is mostly inconsequential.   

One also needs to differentiate between falls and tipping/overturn of the lift. In both, a worker falls, but they are distinctly different in a variety of ways that are obvious.  It should also be noted that some of the fatality reports are improperly classified as falls when in reality they are lifts being tipped, thus overstating the frequency of falls as it relates to scissor lifts.

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Falls Causing the Lift to Tip

Theoretically, it is conceivable that arrested falls could cause the lift to tip over, however data and research on the matter does not support such a theory at this point particularly since most falls from a lift (>80%) involve no PFPS and of the 20% where PFPS was involved, there is limited data indicating a concern with a fall resulting in a lift topping.  There have been a few studies which have involved a drop test and anchorage to the designated anchor points and the rails.   It is hard to draw a conclusion from these studies as the conditions involved (e.g. drop over nose of lift versus the side, on a shorter sized lift, straight drop in an upright mannequin, lift not on an incline etc.) do not fully replicate field conditions and the dynamics involved in a typical fall.  The new CSA and ISO standards require all anchor points for fall arrest to withstand a 300 lb drop test with load placed outside the rails and in a direction to create the most adverse stability condition.  The proposed ANSI/SIA standards have similar language.  Moving forward all new lifts with anchor points for fall arrest will be designed to withstand these impacts and the concern about falling and tipping should no longer be a concern.  One caution here however is that this requirement does nothing to address lifts currently out in the market.  Another important qualification of this standard should also be noted, namely the standard doesn’t require lifts to have anchor points for PFAS but rather sets standards for lifts that do.   If anchor points are only designed for PFRS (not PFAS), as most currently are in the U.S. then these standards do not apply, manufacturers would not be required to undergo this testing and people can continue to be put at risk if using the wrong PFPS.   Presumably manufacturers would provide lifts with the greatest functionality and perform the testing, but is not necessarily required.  All in all, most good evidence points to the notion that lifts tipping over when workers fall out of them is more a theory at this point than a significant concern.  In the future this should be even less of a concern as manufacturers continue to improve on the safety of their equipment.  This all said, regardless of whether a lift has been designed to not tip over in the event of a fall, I am sure someone, somewhere out there will set up a fall protection system with a long lanyard, have it fully elevated, on an incline etc. and prove me wrong.

Sling Shot Effect

The Sling Shot Effect is generally the theory that if a worker is tethered to the lift and the lift topples, that the worker will somehow be slung into the ground, into other surfaces, under the lift etc. via the momentum of the lift falling.  Looking at this with an eye towards the actual physics of the matter versus those observed by Wile E. Coyote one observes several points.   First, two objects of varying mass/weight free falling from the same point in space will hit the ground at the same time.   This of course is not however the reality of a lift being toppled and a worker outside the rails who free falls.  Namely the lift is not in a free fall but in contact with the ground and tipping over through an arc whereas the worker is likely in a free fall if outside the basket.   If the worker is in or on the basket when the lift topples, the worker goes down with the lift at the same rate of speed as the lift does.  If the worker somehow engages a parachute or their flying squirrel suit and the fall is through a great enough distance then perhaps those dynamics change slightly but in the split seconds it takes to fall we can safely assume the worker will impact the ground before, if free falling, or at approximately the same time and there is next to no slingshot action.  Workers who are tethered to the lift and grab on to something overhead as the lift begins to topple could generate some tension on their connecting device and get pulled off of whatever they are grabbing.  In this case, there is the potential for some sling shot effect in theory, but the connecting device and the holding force of the worker likely are not sufficient enough to elastically deform the lanyard so as to appreciably sling shot the worker out in front of the lift.  The only really significant effect approximating the sling shot effect is the angular momentum of the lift as it falls through an arc which would tend to throw the worker in the direction of the fall.   This would essentially be the same whether tethered off or not. 

Jumping Clear

Unless the worker is a parkour master with some precognition or has been bitten by a radioactive super spider, the idea that a worker can prepare and ready themselves to jump clear while the lift falls is extremely unlikely.  The timing is near impossible and when a lift topples, it is usually unexpected and happens very quickly.  This said, there are several instances where users have been able to anticipate the lift tipping and were able to jump and hold on to some overhead object as the lift begins to topple in hopes of being rescued later.  

Though the sample size is small, there is some indication that being tethered to the lift when the lift topples holds an increased risk of injury versus not but more research would need to be done to draw any firm conclusions.   It is also worth noting that most research would indicate that the odds of surviving a fall are better for a worker who rides a lift down and stays inside the basket versus is outside the basket.

Improved positioning of the lift would remove the need to get out of the basket

Improved positioning of the lift would remove the need to get out of the basket

OSHA Requirements

Scissor lift regulations can be found in the relevant section of the scaffold safety orders.   If the guardrail system is fully intact (e.g. up, locked in place, gate closed, proper height etc.), the operator keeps both feet firmly on the platform, no part of their body extends outward beyond the wheels etc., no fall protection is required.   Letters of Interpretation (LOI) and compliance directives provide some additional guidance but are not the law.   What LOI’s and enforcement guides often do however is refer to the non-mandatory Appendix C which references the ANSI/SIA A92.6-1990 standards.  The 1990 version of the standards states that the guardrails shall be installed and access gates or openings are closed per manufacturer's instructions. It then goes on to state that personnel “shall main­tain a firm footing on the platform floor while work­ing.” Otherwise, the ANSI A92-1990 standards are fairly silent when it comes to fall protection and it is not clear how a non-mandatory section of the OSHA regulations which reference an ANSI standard which does not have any language requiring fall protection can be guiding.

More current revisions of the ANSI/SIA standards state:

“The guardrail system of the aerial platform provides fall protection. If occupant(s) of the platform are required to wear personal fall protection equipment (PFPE), occupants shall comply with instructions provided by the aerial platform manufacturer (remanufacturer) regarding anchorage(s).”

It should be noted that the revised ANSI/SIA language has a different meaning than previous versions, namely it has the qualification of “if occupants…are required to wear”.   There are only a few instances where occupants would be required to wear fall protection and those include the removal of the guardrail system, an incomplete guardrail system, mandates by company policy, local requirements etc. Most manufacturers now supply anchorage points but of the top five scissor lift manufacturers in the U.S. only two consistently recommend (not require) users wear a full body harness with a lanyard attached to the authorized anchorage point. One of those manufacturers states that one needs to comply with “applicable government regulations” whereas the other requires that the system be a PFRS.   

Some people use an early version of the 2008 U.S. Army Corps of Engineers (USACE) EM385-1-1 rules as support for fall protection while using a scissor lift because of language such as this:

“Scissors lifts shall be equipped with standard guardrails. In addition to the guardrail provided, if the scissor lift is equipped with a manufactured anchorage, a restraint system shall be used in addition to guardrails.”

The Nov 2014 revision of the USACE EM385-1-1 rules more clearly calls out for a PFRS and in addition to guardrails, that PFRS shall be used provided the lanyard has built-in shock absorbers and is sufficiently short to prohibit workers from climbing out or being ejected from the platform. The rules further prohibit the use of a self-retracting device (SRD) unless permitted by the SRD manufacturer and used in accordance with manufacturer’s instructions. Clearly the USACE offer an opinion about what means of fall protection are required at USACE projects as it relates to scissor lifts. That said, it is important to note that though USACE rules reference OSHA they are not OSHA regulations and only apply to USACE projects.

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As to concerns about OSHA citations of the general duty clause for failure to follow the ANSI/SIA rules, without knowing any specific case where these rules were applied, I would caution that enforcement action supports both positions – for and against wearing fall protection.   Each case, compliance officer, interpretation of the rules etc. is unique and many of us can point to citations which were not justified for a variety of reasons, those that when appealed were vacated etc.   If a worker falls and gets hurt because they were climbing outside the guardrail system with or without PFP, several different rules could be cited including the general duty clause. That said, fear of citations as a reason for doing anything is problematic and certainly less effective than doing it based on sound methodology and value decisions. 

Crush Injuries

Opponents of wearing fall protection while working in the basket sometimes argue that the use of a harness and lanyard can increase the risk of crush injuries if the fall protection equipment gets tangled up in the controls. To be certain there have been instances where such incidents have occurred though they are rare.  It also should be noted that many lifts provide controls against such issues, including secondary triggers like foot pedals, emergency stop buttons which should be engaged once the platform has reached the working height and shuts off power to the control panel, toggle switches which turn off drive and lift functions etc. Further still, most control panels are moveable and thus if work needs to be done in the precise location of the control box, perhaps it is prudent to reposition the lift or relocate the controls.  Last, most of the incidents involving workers getting caught up in the controls have the workers climbing up out of the basket, which for the proponents of PFP is behavior the PFRS, if set up properly, is supposed to prevent in the first place.

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Restraint versus Arrest

There is much debate about the appropriate PFPS that should be implemented.   Breaking it down to basics, most of this discussion centers around issues of practicality.   Listening to the manufacturers, they require PFP, if used, to be a restraint system only.   However, for anyone who has ever done this type of work, a fixed length lanyard of sufficient length to prevent someone from being able to climb up and out of the basket also effectively impacts the ability of the worker to do the work and move around the platform.  To get around these issues, safety professionals often recommend longer lanyards or self-retracting lifelines (SRL’s).   Depending on the set-up, size of the platform and practices used, these systems generally do not work as a restraint system but rather an arrest system, again something the manufacturer prohibits.   Further, though the SRL solves the problem of being able to move and do the work, even with the shortest SRL’s on the market, a worker could easily leave the platform and fall, thus subjecting themselves to the hazards of the fall, striking objects below, potential tipping of the lift etc. particularly given the anchor point is usually below the level of their feet.    

Conflicting Guidance

Some manufacturers and safety professionals demonstrate compliance with fall protection by recommending the use of a 6’ lanyard to the mid rail or designated anchor points of the lift.   There are several challenges with this advice.   Not only would such a system most likely be part of a fall arrest system versus a restraint system, which most manufacturers prohibit, but OSHA guidelines prohibit attaching PFAS to guardrail systems.   If the manufacturers and safety professionals guiding our workers cannot even be consistent our worker’s have little hope.    

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False Sense of Security

Some argue that the use of a PFPS creates a false sense of security.   This could very well be a factor if the wrong decisions are being made.   PFPS’s should be effective and truly provide security.  If they don’t then we are doing something wrong.   As the saying goes, “The operation was a success, but the patient died.”   Mandating that all workers use a harness attached with an SRL that allows workers to leave the basket and not addressing the issues of why workers are leaving the confines of the basket is just such a practice which can create a false sense of security.   Is it better than wearing no protection at all and climbing out of the basket?   Perhaps.  Perhaps not.   It does not necessarily address the issue of eliminating falls and there have been documented incidents where workers fell on lifts and were suspended but still sustained fatal injuries.  Effective free fall distances, with an anchor below one’s feet are also likely to exceed 6’.  Nobody will argue that a PFRS being used that effectively prohibits a worker from being able to climb up on the rails or leave the platform makes it less likely that the worker will fall from the lift.  However, this may not actually allow the worker to perform the work. 

Looks like someone lost the key?

Looks like someone lost the key?

The Elephant in the Room

The crux of the problem lies with why workers are climbing out of the lift in the first place.  Generally, it is because the lift does not allow them access to the area where they need to work.   Unless your crew is filled with a bunch of retired NBA centers, there is probably a need to leave the basket to get the work done.   In looking at these scenarios there are often other issues which factor into this limitation.  Perhaps the lift is the wrong size/type.  Perhaps workers have not properly oriented the lift to the work.  Perhaps a scissor lift is the incorrect means to access this work entirely.  There are a myriad of other possibilities but if we look at one of the biggest root causes in my opinion, is that workers are violating the rules because complying with the rules given the tools they are given to get the work done makes the work infeasible.  Do we really think that those same workers wouldn’t violate other rules like wearing PFP that would similarly keep them from being able to complete their work?  It seems more than reasonable that confining workers to the platform by short lanyards so they can’t climb out of the lift or access materials on the platform would only exacerbate the nature of the problem – namely that workers cannot complete or access the work.  Participation and compliance with a program that does not allow workers to actually do the work is an accident waiting to happen.   It is insane to think that adding more rules will solve the problem of people not following the rules in the first place.  

Accessory Work Platform Attachment

Accessory Work Platform Attachment

If we were able to provide workers a better means to access their work areas then we could potentially limit the risky behavior where workers are required to climb up and/or leave the confines of the basket.   Options include but are not limited to single person vertical lifts, knuckle boom lifts, platform ladders, scaffold systems, improved work sequencing, pre-assembly, tool extensions etc. There are also after market accessory platforms that can be attached to some lifts that have been developed and may potentially improve access challenges and keep people with their feet on the platform.

We can spend all sorts of efforts trying to develop practices to best use a wrench, modifying the wrench itself, training people how to best use the wrench and adding layers of PPE to protect their hands, face etc when using the wrench only to realize that perhaps a hammer was the better tool to drive the nail in the first place. There is a tendency by some safety professionals to equate more as better and unfortunately this is not always the case.  In the hierarchy of controls, PPE should be a last resort but unfortunately for many it is a first resort and little effort is made to eliminate or engineer out the hazards associated with workers accessing their work areas.

It should also be noted, that one of the original purposes of the anchor point on the work platforms was anticipating the need to drop guardrails to presumably better access work areas and thus requiring one to supplement with PFRS.  In practice however, we rarely see this being done and the only times workers really drop the rails is to be able to drive a lift through a doorway or other area of low clearance.   

Bottom Line

Is the use of a PFPS on a scissor lift a safety best practice?  The answer is yes, no and maybe.   Safety determinations are criteria dependent and are contingent on the specific variables present for the task required.   It requires a thorough understanding of the work, the inherent hazards and risks, relevant controls and values etc.  In some situations it may be most prudent to use a PFPS.  In other situations it may not.   It is incumbent on the competent person and safety professional to make a thorough evaluation of each situation and develop work rules and policies for each.  Gravity sucks but after all it is the law.  Hopefully this discussion has provided some additional insights into these operations to assist you as you wade through the challenges of providing the optimal working environment and controls for your workers.   

CEA Leadership In Safety Award

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Each year the Construction Employer’s Association gives out awards to deserving firms and individuals who go above and beyond in the promotion and advancement of health and safety in the construction industry.  Award winners are the who’s who in construction safety and Dr. Kendon Dressel is the latest honoree into this distinguished group. 

Dr. Dressel has a broad background in construction, safety and healthcare.  Starting as a rough carpenter in concrete residential construction, he later worked as a safety and security professional at a large industrial plant, emergency response team member and industrial firefighter.  Other opportunities saw him work as an EMT, a heavy equipment operator, member of an air-mountain rescue team and in shipping, handling and detonating explosives.  He spent 14 years in a leadership role for several large commercial general contractors handling all facets of their risk management and environmental, health and safety programs and guiding their programs to best in class results.  Most recently, he has continued his pursuits with his own company, SALUS, LLC wherein he works full time as an EHS consultant.

I have never been one to sit still for too long and am highly motivated to succeed, particularly when someone says it can’t be done. As a child I was constantly trying to figure out better ways to do things, looking for opportunities and pushing the limits. This made things tough for my parents, but by the age of 14 I already had several businesses.

Kendon is a CSP, CHST and OHST as well as an experienced instructor/lecturer.  His true passion lies in the field of healthcare, where he worked as a licensed Doctor of Chiropractic and Sports Physician.  While running a worker’s compensation and sports injury practice he had the opportunity to work on interdisciplinary teams and with athletes ranging from the industrial and weekend warrior to the Olympic and professional.  Dr. Dressel is a former strength and conditioning specialist, specialist in biomechanics and ergonomics and also has worked as a Independent Disability Examiner. 

It is this broad range of expertise combined with his passion for helping people that has guided his success.   Dressel acknowledges these baseline attributes and motivations but feels the biggest parts of his success are his constant challenges to the status quo, creativity and desire to achieve.   

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Fast forward several years and Kendon left private practice to enter into a relationship with DPR Construction as their corporate doctor/safety professional.   “I was at a hockey game with some executives from DPR and trying to sell them on all the unique services I could provide.  I had some big ideas and didn’t really have much hope that they would be interested but I knew their reputation for pushing the envelope.  True to their vision they brought me aboard and shortly thereafter I was developing their Stretch & Flex program.”   That program, part of an extensive soft tissue management program, was one of the first of its kind in the industry and is now something widely used across the construction industry.

Dressel was also involved in Beta testing and working on the ground floor of what was perhaps the first digital safety audit/inspection system.   That system became DBO2 SafetyNet, perhaps the leading system in the industry.   “I was searching for better and more efficient ways to conduct safety audits.   The timing couldn’t have been better and soon thereafter, Dr.  Jon Moldestad and I were developing and testing safety inspections on the original Palm Pilot, something unheard of in the industry at that time.”   

I have always welcomed a challenge. I remember brainstorming a system that would measure safety leading indicators and serve to bring consistency and accountability across the organization. People told me it couldn’t be done, and if it could, it would be too complex and cumbersome to gain wide use. A few weeks later I rolled out the ‘Consistency Survey’ which was essentially a project report card that measured project deliverables and safety systems, provided raw scores and added instant accountability. I started beta testing it in one regional office, people quickly saw the benefits and soon it was adopted company wide.

Every organization that Kendon has been involved with has improved their safety performance.    Kendon would be the first to point out that ultimately the success of an organization is the culmination of the entirety of people’s efforts and no single person can be responsible for that success, however Kendon has more than demonstrated his ability to lead and spearhead efforts.  Early in his career, his involvement at an industrial plant led to over 3 years without an incident.  At DPR he took an already good program and made it better.  At Nibbi, the incident rate was 17 when he was hired and it went to zero in less than 3 years, including almost a million hours of injury free self-performed structural concrete work, culminating in the achievement of VPP-C status. 

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Safety professionals are a unique group.  Not only do many have post-secondary degrees, but they are some of the more highly trained workers in the industry in the way of course work, continuing education, certifications and technical knowledge.   They are pitted daily into conflict, having to convince people to do things they otherwise don’t want to do and have to be adept at communicating, problem solving, dealing with difficult people, planning, budgeting, management etc.   They have to deal with trade workers and executives, office and field, owners, insurers, and government agencies.   Further, to be most effective, they have to intimately understand each trade’s work process and methods, as well as the general characteristics of the people within that trade.  There are a few folks who can do this and do it well and Dr. Dressel is one. 

One question that many people ask was why he left his work as a doctor to come to work as a safety professional in construction.   Few would make this jump and take the risk to basically break new trail in an industry known for being slow to embrace change.  His answer, “I saw the results of people working unsafe on my exam table all the time and I knew that I had some unique skills and expertise that were lacking in the construction industry.   I felt there was a real opportunity to effect change and make something special happen and I took that leap.”  There are many who are happy he did.