Scaffolding Safety Awareness Program

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1 Page 1 of 6 Sect: 1.0 Purpose 2.0 Scope While Ardent employees do not erect or modify scaffolding, it is essential that they understand and follow standard industry scaffold tagging procedures when accessing scaffolds and that they have the knowledge necessary to spot potentially unsafe scaffolding conditions irrespective of the tagging system. All company operations shall use the, both in business units and project operations, wherever employees are required to work at elevations requiring the use of scaffolding. 3.0 Regulatory References This is primarily intended to satisfy the following regulatory requirements: o 29 CFR , Cal/OSHA Title 8 CCR Responsibilities 4.1 Management Ardent Management is responsible for the following: Ensure that the HSE Management System adequately addresses Scaffold Safety Awareness and that the policy is reviewed annually and revised as necessary. Provide Awareness training for all employees. Provide leadership and support for employees in communicating their responsibility to stop the work when unsafe conditions are behaviors are discovered or suspected. Provide resources to address and correct any Awareness related issues. 4.2 Supervision Ardent Supervision is responsible for the following: Understand and enforce the Ardent. Provide guidance to employees on recognition and control of scaffolding related hazards. Identify and designate a competent person responsible for scaffold inspections. Provide immediate on-the-spot training for all employees on the jobsite regarding Awareness when necessary. Report scaffolding related Accidents and Near Miss events. Enforce access rules and provide discipline as necessary for scaffolding violation.

2 Page 2 of 6 Sect: 4.3 Employees Ardent Employees are responsible for the following: Check scaffold tags prior to accessing any scaffold and follow instructions. Participate in and understand Awareness training. Follow safety rules and guidelines regarding. Participate in JSA and hazard recognition activities. Make every effort to identify scaffold related hazards during daily JSA s. Stop the work and immediately inform your supervisor if you believe a scaffold is unsafe or presents hazards that have not been identified and/or for which control measures have not been implemented. Tag-out or barricade any unsafe condition. Follow and use all fall protection requirements and PPE. 5.0 Policy & Procedure 5.1 Restrictions - Ardent employees are not allowed to erect or modify scaffolding. Employees are not allowed to use scaffolding unless the scaffolding has been inspected and approved for use as indicated by the appropriate tag. Employees are not allowed to use rolling scaffolding. 5.2 Disciplinary Action - Only trained, qualified and authorized individuals are to erect, modify and inspect scaffold. Any non-authorized employee attempting to erect or modify scaffold shall be subject to disciplinary action up to and including termination of employment. 5.3 Inspection by Competent Person - Scaffolds and scaffold components shall be inspected for visible defects by a competent person before each work shift, and after any occurrence which could affect a scaffold's structural integrity. 5.4 Tagging - The following simple color code tagging system is applicable to all scaffolding at all work sites and must be followed with no exceptions. These tags are to be applied and updated only by the authorized individuals responsible for scaffold inspection. Red Tag: Yellow: Green: Scaffolding is not approved for use. Under no condition is an employee allowed to access red tagged scaffolding. Use of scaffolding is conditional. Employees must read and follow conditional instructions on the tag to use the respective scaffolding. Scaffolding is approved for use. Examples:

3 Page 3 of 6 Sect: 5.5 Load Ratings The design load of all scaffolds shall be calculated based on: 1) Light -Designed and constructed to carry a working load of 25 pounds per square foot. 2) Medium -Designed and constructed to carry a working load of 50 pounds per square foot. 3) (Heavy -Designed and constructed to carry a working load of 75 pounds per square foot Each scaffold and scaffold component shall support, without failure, its own weight and at least 4 times the maximum intended load applied or transmitted to it. Scaffolds and scaffold components shall not be loaded in excess of their maximum intended loads or rated capacities, whichever is less. 5.6 Wheels or Casters 1) Wheels or casters shall be properly designed for strength and dimensions to support 4 times the design working load. 2) All scaffold wheels, casters and swivels shall be provided with a positive locking device, or other effective means to prevent movement of the scaffold. 3) Ladder stands shall have at least 2 locking casters or other means of locking the unit in position. If only 2 casters are used, they shall be of the directional type and if 4 casters are used, at least 2 of the 4 shall be of the swivel type. 4) Locking devices shall be kept in the locked position when workers are climbing or working on scaffolds and ladder stands. 5) Where leveling of the elevated work platform is required, screw jacks or other similar means for adjusting the height shall be provided in the base section of each mobile unit. The screw jack shall extend into its leg tube at least 1/3 its length, but in no case shall the exposed portion of the screw jack exceed 12 inches. 5.7 Defects - All deficiencies and defects shall be tagged. The competent authorized person responsible for inspecting scaffold shall determine the appropriate action or access level by applying the appropriate color tag. All employees must comply with instructions on scaffold tags. Any employee may tag-out, flag or barricade an unsafe condition. An example of a tag-out tag that may be applied to an employee discovered defect or deficiency is show to the right. 5.8 User Visual Inspection - Inspection and tagging of scaffolding will be carried out by trained, competent and authorized individuals; however, it is important

4 Page 4 of 6 Sect: that employees perform a visual inspection of scaffolding prior to use regardless of existing tags. In general, employees should look for the following: 1) Supported scaffold poles, legs, posts, frames, and uprights shall bear on base plates and mud sills or other adequate firm foundation. Footings shall be level, sound, rigid, and capable of supporting the loaded scaffold without settling or displacement. Unstable objects shall not be used to support scaffolds or platform units. 2) Toe boards should be in place to prevent objects from falling from the platform. 3) Each platform on all working levels of scaffolds shall be fully planked or decked between the front uprights and the guardrail supports. 4) Supported scaffolds with a height to base width (including outrigger supports, if used) ratio of more than four to one (4:1) shall be restrained from tipping by guying, tying, bracing, or equivalent means. 5) All platforms must be at least 20 wide. 6) Planks and platforms should be fastened to the scaffold as necessary to prevent uplift or displacement. 7) Scaffold equipment should not be rusty or corroded 8) Guardrail systems shall be installed along all open sides and ends of platforms. Guardrail systems shall be installed before the scaffold is released for use by employees other than erection/dismantling crews. 5.9 Fall Protection - Full body harnesses must be worn when working off scaffolding. Employees are not required to tie off when working off green tagged scaffolding. Yellow tag scaffolding may require tie off as a condition for use and in such cases, employees must comply with tie off requirements General Guidelines - Employees should use care and good judgment when using scaffolding. Some general guidelines for scaffolding use are: 1) Always check the scaffold tag before accessing scaffold. 2) When scaffold platforms are more than 2 feet 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. Cross braces shall not be used as a means of access. 3) Access work platforms using safe convenient methods. 4) Do not carry materials when climbing onto scaffolding. Keep both hands on the side rails or ladder

5 Page 5 of 6 Sect: 5) Employees shall be prohibited from working on scaffolds covered with snow, ice, or other slippery material except as necessary for removal of such materials. Work on or from scaffolds is prohibited during storms or high winds unless a competent person has determined that it is safe for employees to be on the scaffold and those employees are protected by a personal fall arrest system or wind screens. 6) Scaffolds shall not be erected, used, dismantled, altered, or moved such that they or any conductive material handled on them might come closer to exposed and energized power lines than as follows: Less than 50 kv- 10 feet More than 50 kv- 10 feet plus 0.4 inches for each 1 kv over 50 kv. 7) Overhead protection must be provided when persons using scaffolding are exposed to overhead hazards. 8) Loads on the planks should be evenly distributed 9) In addition to wearing hardhats, each employee on a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects through the installation of toe boards, screens, or guardrail systems, or through the erection of debris nets, catch platforms, or canopy structures that contain or deflect the falling objects. When the falling objects are too large, heavy, or massive to be contained or deflected by any of the above-listed measures, the employer shall place such potential falling objects away from the edge of the surface from which they could fall and shall secure those materials as necessary to prevent their falling. 6.0 Training Ardent will provide Awareness training. This training shall be conducted by a qualified/competent person capable of recognizing the hazards associated with the types of scaffold systems being utilized and methods/ procedures for controlling such hazards. If conditions not covered by the previous Awareness training are encountered or new scaffold types are introduced to the jobsite, all affected employees must be re-trained. 6.1 Training Content Content includes: 1) Purpose & Policy 2) Employee Responsibilities 3) Inspection & Tagging System (Disciplinary Action) 4) Hazard Recognition Fall Hazards Electrical Hazards

6 Page 6 of 6 Sect: Falling Object Hazards 5) Methods and Procedures for Controlling Hazards Personal Fall Protection System Controlling Electrical Hazards Encountered on Scaffolds Methods of Protection from Falling Objects 6) Material Handling on Scaffolds 7) Determining Load Capacity of Scaffolds 8) Reporting & Documentation 6.2 Personnel Training All Ardent employees shall receive training. 6.3 Training Frequency Awareness training shall be included in the Short Service Employee Program and will be covered in first 180 days of service or prior to new employees utilizing scaffold systems. Awareness training shall also be refreshed annually as part of the Toolbox Safety Meeting Program. When the there is reason to believe that an employee lacks the skill or understanding needed for safe work involving the erection, use or dismantling of scaffolds, the employer shall retrain each such employee so that the requisite proficiency is regained. Retraining is required in at least the following situations: Where changes at the worksite present a hazard about which an employee has not been previously trained, Where changes in the types of scaffolds, fall protection, falling object protection, or other equipment present a hazard about which an employee has not been previously trained, or, where inadequacies in an affected employee's work involving scaffolds indicate that the employee has not retained the requisite proficiency. 7.0 Reporting and Recordkeeping 7.1 Reports All scaffold related incidents shall be reported Incident/Accident Report - All scaffold events resulting in injury, illness, or loss of consciousness of an employee shall be recorded as Incidents on an Ardent Incident Report Near Miss Reports - Failures in control methods not resulting in employee injury shall be recorded as near miss events on an Ardent Near Miss Report. Examples: Tools falling from scaffold due to missing toe board, or employee discovering an unsecured board on a green tag scaffold.