OSHA Releases New Statement on Material Storage on Scaffolding
On August 12, 2003, MCAA met with the Directorate of Construction of OSHA at their offices in Washington DC. Though we discussed numerous issues, the major issue was the OSHA interpretation of 06/10/2003 - Storage of materials that prevents inspection of scaffolds before work shifts; incidental storage amounts that do not inhibit scaffold inspection. Realizing that this letter of interpretation could have a significant safety impact on the masonry industry, we wrote OSHA a follow up letter outlining our concerns.
According to the aforementioned interpretation, the mason is required to remove all unused material at the end of the work shift. Whenever masonry materials are moved, there exists a potential safety hazard. Multiple handling of masonry materials unnecessarily increases the risk of injury. This requirement presents some safety concerns that the MCAA thought OSHA may have overlooked, such as:
- Unloading a partial cube of loose masonry units increases the risk of one or more units falling from the cube. Although there are such things as manual bands, they will not provide an acceptable level of safety to masons;
- In many cases, unloading masonry materials after the work shift will require the laborers to partially disassemble guardrails and other portions of the scaffolding to provide forklift or crane access to the materials;
- The forklift operators will be required to unload the material "blind", thus increase the likelihood of handling errors and making this activity unsafe;
- In the case of hydraulic powered scaffolding, the scaffolding will need to be lowered so that the forklifts can reach the material to be unloaded. Increasing the frequency of this activity, in our view, is also potentially unsafe;
- In most urban areas, space constraints are almost always a problem. In today's construction management practices of "on-time delivery", materials are delivered onto the site when they are intended for use. Thus, there will be no space to store materials outside of the scaffolding;
- Masonry materials are often used to weigh down scaffold planks in the case of severe wind. Incidental amounts of materials can provide stability and help prevent uplift of the scaffold planks throughout the night that may be caused by severe wind or inclement weather.
OSHA agreed with our statements and issued a revised interpretation. This revised interpretation states that OSHA will not write any citations for material stored on scaffolding. If a general contractor requires a mason to remove his material from the scaffolding, it shall be deemed a de minimis violation. (Citations are not issued for de minimis violations.)
This is an example of MCAA's growing presence in both the governmental and the codes and standards portion of the construction industry. This is a big win for mason contractors and the masonry industry as a whole. Thanks should go to the MCAA staff for their efforts in this matter.
About the Author
Rashod R. Johnson, P.E., is president of The Roderick Group in Chicago. He is the former Director of Engineering for the Mason Contractors Association of America and currently serves as a technical consultant to the association.