As a concrete contractor, you are familiar with shoring equipment that is used to support elevated concrete slabs during construction. But did you know that the shoring equipment may be classified as scaffolding? This should concern you since your employees deserve a safe worksite and you need to ensure you and your employees comply with the applicable safety standards.
While the specific project and jurisdiction will determine the applicable mandatory safety standards, typically the OSHA construction industry standards, 29 CFR 1926, will apply to both concrete construction and scaffolding. But how do these standards apply? Generally, there are four subparts that may apply to concrete construction involving shoring. They are L-Scaffolds, M-Fall Protection, Q-Concrete Construction, and X-Stairways and Ladders. Knowing how these subparts apply to your specific situation is important since there are multiple regulations addressing similar hazards. For example, there are fall protection regulations in the scaffolding subpart that supersede the fall protection requirements in Subpart M. There are access requirements in Subpart X that do not apply to scaffolding but do apply to shoring towers. It is up to you, the employer or employee, to know which regulations apply.
To determine when the scaffold standards apply, you must ask yourself if the elevated platform upon which you are standing is indeed a scaffold. A scaffold is “any temporary elevated platform and its supporting structure used for supporting employees or materials or both.” On the other hand, the formwork for a concrete deck is a walking/working surface which is “any surface on which an employee walks or works.” While one might think that horizontal formwork for an elevated concrete floor would be considered a temporary elevated platform, such is probably not the case. It is the purpose of the platform that determines whether it is a scaffold platform or a walking/working surface. The purpose must be determined so that the correct regulations can be applied. If you have constructed the platform so that employees can stand on it to do their work, then it is a scaffold; alternatively, if the platform is there so that it can support concrete, it is not a scaffold but rather a walking/working surface. For example, the platform that is supported by brackets mounted to the side of a wall form is a scaffold since its purpose is to support workers placing concrete in the wall form. Another example is the temporary walkway around the perimeter of a formwork deck; it is a walking/working surface. Here are several variations in the standards that illustrate the importance of knowing whether you have a scaffold platform or a walking/working surface:
Falling object regulations occur in both the scaffold standards and the fall protection standards. While Subpart L applies to workers who are on a scaffold, Subpart M applies to workers passing under a scaffold. Fortunately, there is agreement in one area: If a portable ladder is used to access either a scaffold or a shoring platform, it must comply with the regulations of Subpart X. Also keep in mind there are variations with other jurisdiction, including California and the U.S. Army Corps of Engineers.
Confused? Simply ask: Is this platform elevated because I need to reach my work or is it being used to support concrete? If it is elevated to reach the work, it’s a scaffold. If not, then it is a walking/working surface. In any event, it is the safety of the worker that is paramount; if in doubt abide by the stricter regulation.
David Glabe, P.E., is founder of DH Glabe & Associates, a nationally recognized construction engineering firm specializing in scaffolding, shoring, forming, and unique construction issues. He also provides construction safety training for contractors and OSHA institutes and serves as an expert witness in construction-related legal matters. He can be contacted at firstname.lastname@example.org.