International Environmental Health and Safety (IEHS) Section 8 Walking/Working Surfaces 8.1 Objective The Walking/Working Surfaces program has been developed for IEHS and project employees working on site, under contract to IEHS who in the course of their work will be exposed to unprotected and/or unguarded openings, walkways, erection of scaffolds, or other temporary structures. The following information provides guidance and direction to the Site Safety Team, listed site competent person(s), subcontractor H&S representatives, or their designees for implementation of IEHS s Walking/Working Surfaces Program. 8.2 Roles and Responsibilities Competent Person The competent person is responsible for understanding the requirements of the role for projects that require scaffolding to complete scope tasks. The competent person must be knowledgeable regarding the requirements for scaffold use (29 CFR 1926.451). Subcontractors will determine who will serve as their competent person(s). The competent person shall also: Perform program inspections and audits in conjunction with other site H&S representatives. Document all findings of audits that are performed. Report any safety violations to IEHS s Site Safety Team. 8.3 General Requirements Walking/Working Surfaces Determine if walking and working surfaces have the strength and integrity to support employees safely. Do not overload floors with materials and/or equipment over the approved load limits. Mark elevated storage and other platforms with the load bearing weight. 8-1 Copyright ISM 2013
Ensure all aisles and passageways are clearly marked; have adequate space for passage of both moving equipment and employees; have safe clearances at all turns, doors, and passageways; and are not obstructed by physical barriers and/or stored materials. Provide and maintain guardrails to protected employees from falling to a lower level, or onto equipment. Standard guardrails must have a toeboard, midrail, top rail, and posts meeting the applicable regulatory requirements. Employees working on a steep slope roof (greater than four inches of run per twelve inches of rise) that are six feet or more above a lower level must be protected from falls by a guard rail system, personal fall arrest system, or safety net system. Employees working on low slope roofs (less than or equal to four inches of run per twelve inches of rise) with unprotected sides and edges that are six feet or more above a lower level are to be protected by either a guard railing system, a personal fall arrest system, a safety net system, a combination of a warning line and any other of the preceding systems, or a combination of a warning line and a safety monitor. Provide proper guarding for floor openings, open pits, ditches, and other open areas by covering or guarding with a standard railing. If the opening is not guarded or covered, it must be protected by a temporary barrier on all exposed sides or attended by an assigned person. Scaffolding Scaffolds shall be designed by a competent person and shall be constructed and loaded in accordance with such design. Each scaffold and scaffold component shall be capable of supporting, without fail, its own weight and at least four times the maximum intended load applied or transmitted to it. Supported scaffolds shall be erected on stable surfaces with poles, legs, posts, or frames on base plates, mud sills, or other adequate foundations. The scaffold competent person shall supervise and direct all scaffold erection, moving, dismantling, or alteration activities. Modification of scaffolding components by unauthorized employees will not be tolerated. Employees found in willful violation of this policy will risk disciplinary action as outlined in IEHS s H&S Discipline Program. The scaffold competent person shall inspect all construction scaffolds and their components for visible defects before each work shift and after any occurrence that could affect the scaffold s structural integrity. During storms or high winds, work shall not be conducted on scaffolds unless the competent person has determined that it is safe, and the scaffold users on the scaffold are protected. The competent person shall determine the proper access and fall protection systems for scaffold users during scaffold erection and dismantling. 8-2 Copyright ISM 2013
Pole scaffolds over 60 feet in height shall be designed by a registered Professional Engineer, and shall be constructed and loaded in accordance with that design. Tube and coupler or fabricated frame scaffolds over 125 feet in height shall be designed by a registered Professional Engineer and shall be constructed and loaded in accordance with such design. Each employee working on a scaffold six (6) feet or greater in height shall be protected from falling through the use of a guardrail system, safety nets, or PFAS. During assembly of scaffolding, the lead man shall not be required to tie off (preapproval by the Site Safety Team is required before starting work); all other employees must follow the requirement set forth in IEHS s Fall Protection Program. Guardrail systems shall be installed along all open sides and ends of platform before the scaffold is released to employees other than those employees involved in erection and/or dismantling operations. Scaffolds shall be tagged by the designated scaffold competent person prior to releasing the scaffold for general use. The tag shall be color coded to indicate the condition of the scaffold and initialed and dated by the scaffold competent person. Color codes RED = do not use. YELLOW = scaffold may be used, but additional requirements are necessary for use such as a PFAS is required. GREEN = scaffold is complete and ready for use as a legal platform. Access Scaffolds Safe means of access shall be provided to each employee erecting or dismantling a scaffold where the provision of safe access is feasible and does not create a greater hazard. When scaffold platforms are more than two feet above or below a point of access, portable ladders, attachable ladders, stair towers, 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. 8-3 Copyright ISM 2013
Hook-on and attachable ladders shall be positioned so that their bottom rung is not more than 24 inches above the scaffold supporting level. If hook-on and attachable ladders are used on a supported scaffold more than 35 feet high, they shall have rest platforms at 35 feet maximum vertical intervals. Hook-on and attachable ladders shall be specifically designed for use with the type of scaffold used. Scaffold Platforms Scaffold platforms, at all working levels, shall be fully decked between the uprights and the guardrail supports once a scaffold has been released for general use. Scaffold planks and/or decks used to create the overall scaffold platform shall be installed so that the space between the adjacent units and the space between the platform uprights is no more than 1-inch wide, except where it can be demonstrated that a wider space is necessary. Scaffold planks utilized on site must be designed specifically for the purpose of scaffolding and constructed of heavy duty standard. The front edge of scaffold platforms shall be no more than 14 inches from the face of the work surface unless a guardrail system that complies with the requirements of this section is erected. The distance allowed from the face of the work surface to the edge of the scaffold platform shall not be greater than three inches for outrigger scaffolds. Each end of a scaffold platform, unless cleated or otherwise restrained by hooks or other means to prevent movement or tipping, shall extend over the centerline of its support a minimum of six inches; however, shall not extend greater than 12 inches. All scaffold platforms and walkways shall be a minimum of 18 inches wide. On scaffold platforms where scaffold planks are abutted to create a long platform, each abutted end shall rest on a separate support surface and be cleated, or otherwise secured to prevent movement or tipping. On scaffold platforms that overlap scaffold planks to create a long platform, overlap shall only occur over supports, and planks shall overlap each other a minimum of 12 inches unless the overlaps are nailed or otherwise secured one to the other. Toeboards shall be erected along the edge of platforms 10 feet or more above a lower level to prevent debris and other materials from falling to lower levels. Guardrail Systems for Scaffolding Guardrail systems shall be installed along all open sides and ends of platforms. They shall consist of a top rail, midrail, and toeboards, which must be installed before the scaffold is released for employee use other than the erection/dismantling crews. Top rails shall be installed between 38 inches and 45 inches above the platform surface. They shall be able to withstand, without failure, a force applied in any downward or horizontal 8-4 Copyright ISM 2013
direction at any point along its top edge of at least 200 pounds. For suspension scaffolds, the top rail shall withstand, without failure, a force applied in any downward or horizontal direction of at least 100 pounds. Midrails shall be installed halfway between the top rail and the platform. They shall be able to withstand, without failure, a force applied in any downward or horizontal direction of at least 150 pounds. For suspension scaffolds, the midrail shall withstand, without failure, a force applied in any downward or horizontal direction of at least 75 pounds. Toeboards shall be installed at the outermost edge of the platform and not have more than ¼- inch clearance above the platform. They shall be at least 3 ½ inches in height and be able to withstand, without failure, at least 50 pounds applied in any downward or horizontal direction at any point along the toeboard. Falling Debris Protection Each employee working on or around scaffolding shall be required to wear a hard hat. In addition, each employee on or below a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects through the installation of toeboards, screens, guardrail systems, or through the erection of debris nets, catch platforms, or canopy structures. When the falling objects are too large, heavy, or massive to be contained or deflected such objects shall be placed away from the edge of the surface from which they could fall and shall be secured to prevent their falling. Criteria for Supported Scaffolds Supported scaffolds with a height-to-base width ratio of greater than 4:1 shall be restrained from tipping by guying, tying, bracing, or other equivalent means. Guys, ties, and/or braces shall be installed to the scaffolding manufacturer s recommendations or at the closest horizontal member to the 4:1 height. They shall be installed horizontally at each end of the scaffold at the 4:1 height and at intervals not to exceed 30 feet thereafter. This process shall be repeated vertically at intervals not to exceed 20 feet. Supported scaffold poles, legs, posts, frames, and uprights shall bear on base plates, mudsills, 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. Unstable objects shall not be used as working platforms. Front-end loaders and similar pieces of equipment shall not be used to support scaffold platforms unless they have been specifically designed by the manufacturer for such use. 8-5 Copyright ISM 2013
Suspended Scaffolding Suspended scaffolding shall not be used by IEHS employees or subcontractors working on site, without written approval from the DHS of IEHS. Illumination Construction areas, aisles, stairs, ramps, runways, corridors, offices, shops, and storage areas where work is in progress shall be lighted with either natural or artificial illumination in accordance with 29 CFR 1926.56. Employees may not enter spaces containing exposed energized parts unless illumination is provided that enables the employees to work safely. Where lack of illumination or an obstruction precludes observation of the work to be performed, employees may not perform tasks near exposed energized parts. Employees may not reach blindly into areas which may contain energized parts. Housekeeping This safety policy is established in accordance with Occupational Safety and Health Standards for Construction Industry (29 CFR 1926.25). It is the policy of IEHS to provide a place of employment that is free from recognized hazards that cause or are likely to cause death and serious physical harm to employees or the public. Therefore, all employees on the project site will practice good housekeeping to further reduce hazards to employees. When construction hazards exist that cannot be eliminated, then engineering practices, administrative practices, safe work practices, Personal Protective Equipment (PPE), and proper training regarding Housekeeping will be implemented. These measures will be implemented to minimize those hazards to ensure the safety of employees and the public. It is the responsibility all employees on the project site to ensure implementation of IEHS s safety policy on Housekeeping. It is also the responsibility of each employee to report immediately any unsafe act or condition to his or her supervisor. Scrap material and debris generated during construction usually consist of non-combustible scrap material and debris and combustible scrap material and debris. Non-combustible scrap material and debris that consist of form and scrap lumber with protruding nails and all other debris must be kept cleared from work areas, passageways, stairs, and from around buildings or other structures. Nails should be removed from used lumber before stacking. Combustible scrap and debris must be removed at regular intervals during the course of construction without increasing the hazard exposure to employees who remove such debris. All construction waste must first be collected into containers before disposal. The categories of construction waste generated at a construction site include general waste and trash (non-toxic, 8-6 Copyright ISM 2013
non-hazardous) and hazardous waste. Separate containers must be provided for the collection and separation of waste, trash, and other refuse. Additional separate containers must be provided with lids for hazardous wastes to prevent sparks or other ignition sources from coming into contact with hazardous waste. Hazardous wastes can include used oil, used oil filters, oily rags, and flammable wastes as well as caustics, acids, harmful dusts, etc. Absorbent that is used to collect incidental used oil spills and oily rags can be disposed of in waste collection receptacles. Used oil filters must be drained of oil before they can be disposed into separate waste containers. All project employees will be made aware of the importance, benefits, and requirements of housekeeping related to their specific job duties during site-specific orientation. Portable Ladders Only portable ladders constructed of fiberglass are permitted on the project site. The reasons for this are: 1) fiberglass is non-conductive whereas aluminum is not, 2) fiberglass is durable and less fragile or ductile than aluminum or wood, and 3) fiberglass ladders are easier to inspect for damage and flaws than wood since there may be internal flaws in the grain that cannot be visualized. Do not stand on either of the top two steps of a stepladder. Note: Platform ladders are excluded from this since they utilize a platform on the top level of the ladder for this express purpose. Stepladders must be fully opened to permit the spreader lock to engage the safety latch. Broken or damaged ladders must be removed from service, marked, and discarded. Never use a damaged ladder. All extension ladders must be securely tied off at the top and extend three feet beyond the step off point, and A-frame ladders must similarly either be held by another co-worker or tied off to prevent them from tipping over. The base of an extension ladder must be set back a safe distance from the vertical - approximately ¼ the working length of the ladder, for every 4 feet in rise, the base of the ladder should be 1 foot away from the supporting wall or horizontal structural steel/pipe that supports it (4:1 ratio). Ladders used for access to a floor or platform must extend at least three feet, or four rungs, above the landing. You must face the ladder when ascending or descending. The feet of the ladder must be on a solid base, and the area around the top and bottom of the ladder must be kept clear. When setting up a ladder, ensure the ground, floor, or grating it is set upon is level and stable. Do not attempt to set up a ladder on a slippery or wet surface. Before using a ladder, inspect it for faults such as cracked rungs or rails. If any defect is found, tag or disable the ladder and remove it from service. 8-7 Copyright ISM 2013
Do not use materials to raise the height of the ladder. If it is not tall enough, you are using the wrong ladder. When using a stepladder, ensure the folding cross braces are locked in the proper position before you step onto it. Remember the 3-Point Rule : at least two hands and one foot, or two feet and one hand should be in contact with the ladder at all times. All employees working from a ladder will use a body harness and lanyard for fall protection whenever they climb higher than 6 feet and stop to conduct work from the ladder and cannot maintain three points of contact. 8.4 Training All IEHS project employees working on site will receive training during site-specific orientation regarding the identified hazards associated with work involving walking/working surfaces. The following training shall be provided by a scaffold qualified person to those employees who meet the definition of the titles below: General Employees Who Work from or Use Scaffolding The topics to be covered will include: The nature of any electrical hazards, fall hazards, and falling object hazards in the work area. The correct procedures for dealing with electrical hazards and for erecting, maintaining, and disassembling the fall protection systems and falling object protection systems that are to be used. The proper use of the scaffold and the proper handling of materials on the scaffold. The maximum intended load and the load-carrying capacities of the scaffolds used and any other pertinent requirements of the regulation. Employees Who Erect Scaffolding The topics to be covered will include: The nature of the scaffold hazards. The correct procedures for erecting, disassembling, moving, operating, inspecting, and maintaining the type of scaffold used. The design criteria, maximum, intended load-carrying capacity, and intended use of the scaffold. 8-8 Copyright ISM 2013
Scaffold Competent Person The competent person shall have specific training and be knowledgeable about the structural integrity of scaffolds and the degree of maintenance needed to maintain the scaffolds and the applicable scaffold regulations. Retraining is required when an employee s supervisor or scaffold competent person has reason to believe that an employee lacks the skill and understanding needed to safely work from, erect, or dismantle a scaffold or where changes at the work site present a hazard about which the employee has not been trained. Documentation of training for each category shall be maintained at the project site for the duration of the project. This documentation shall at a minimum provide the following information: Date of training Employee name Purpose of training Instructor s name and signature 8.5 Audits and Inspections Monthly audits of scaffolding utilization and compliance with established guidelines will be conducted by the Site Safety Team, subcontractor s H&S representative, or their designees, as outlined within IEHS s H&S Inspection/Audit Program. These audits shall be documented in the project files and deficiencies shall have timely corrective action measures defined. The auditor will be responsible for ensuring that corrective measures are met within the established time frame and must report any non-compliance to the PM for immediate follow-up including, but not limited to, disciplinary action as outlined in IEHS s H&S Discipline Program for the affected individuals. Employees shall perform pre-job inspections of the scaffolding before use. The competent person shall inspect all construction scaffolds and their components for visible defects before each work shift and after any occurrence that could affect the scaffold s structural integrity. These inspections shall be documented and copies provided to the Site Safety Team. Scaffolds shall then be marked with scaffold tags in accordance with the requirements of this program. 8.6 Documentation All training, implementation audits, scaffold inspections and subcontractors documentation of the same shall be maintained by the Site Safety Team in the project file on site. Records of noncompliance (personal and company) shall be maintained in the associated employee s or subcontractor s files for the duration of the project. 8-9 Copyright ISM 2013