Part One: Fall Protection on Completed Scaffolds

Determining the type of fall protection system used on scaffolds is complex for many reasons. Points to consider include their  varying types, utilized locations, strength of components, availability of personal fall arrest system anchorage points, and requirements on already completed versus to-be-erected scaffolds, to name a few. Fall protection systems on completed scaffolds are generally one of two systems—a guardrail fall protection system or a personal fall arrest system (PFAS). The type of scaffold determines the system required by OSHA regulations, which are as follows:

1926.451(g) Fall Protection:

(1) Each employee on a scaffold more than 10 ft. (3.1 m) above a lower level shall be protected from falling to that lower level.  Paragraphs (g) (1) (i) through (vii) of this section establish the types of fall protection to be provided to the employees on each type of scaffold. Paragraph (g)(2) of this section addresses fall protection for scaffold erectors and dismantlers.  Note to paragraph (g)(1): The fall protection  requirements for employees installing suspension scaffold support systems on floors, roofs, and other elevated surfaces are set forth in subpart M of this part.

(i) Each employee on a boatswains’ chair, catenary scaffold, float scaffold, needle beam scaffold, or ladder jack scaffold shall be protected by a personal fall arrest system;

(ii) Each employee on a single-point or two-point adjustable suspension scaffold shall be protected by both a personal fall arrest system and guardrail system;

(iii) Each employee on a crawling board (chicken ladder) shall be protected by a personal fall arrest system, a guardrail system (with minimum 200-lb. (90.80 kg) toprail capacity), or by a three-fourth inch (1.9 cm) diameter grabline or equivalent handhold securely fastened beside each crawling board;

(iv) Each employee on a self-contained adjustable scaffold shall be protected by a guardrail system (with minimum 200 lb. (90.80 kg) toprail capacity) when the platform is supported by the frame structure, and by both a personal fall arrest system and a guardrail system (with minimum 200 lb. (90.80 kg) toprail capacity) when the platform is supported by ropes;

(v) Each employee on a walkway located within a scaffold shall be protected by a guardrail system (with minimum 200 lb. toprail capacity) installed within 9.5” (24.1 cm) of and along at least one side of the walkway.

(vi) Each employee performing overhand bricklaying operations from a supported scaffold shall be protected from falling from all open sides and ends of the scaffold (except at the side next to the wall being laid) by the use of a personal fall arrest system or guardrail system (with minimum 200 lb. (90.80 kg) toprail capacity).

(vii) For all scaffolds not otherwise specified in paragraphs (g)(1)(i) through (g)(1)(vi) of this section, each employee shall be protected by the use of personal fall arrest systems or guardrail systems meeting the requirements of paragraph (g)(4) of this section.

The Regulation Breakdown

Only a PFAS is required on scaffolds listed in subpart (i), while subpart (ii), which applies to single-point and two-point suspended scaffolds, requires a guardrail fall protection system and a personal fall arrest system.

Section (vii) applies to the most supported scaffolds (frame, tube and coupler, system, wood pole, etc.).  It allows the use of either a guardrail fall protection system or a PFAS, with the guardrail fall protection system as the first choice. The PFAS is to be used where guardrails are not feasible, such as when guardrails are temporarily removed to load material onto the scaffold. Some employers, however, have a site specific policy that requires both a guardrail fall protection system on the scaffold and the implementation of a PFAS. For contractors working in the oil and gas industry, implementation of both systems is common practice. And while the OSHA trigger height for fall protection on scaffolds is 10 ft., guardrails on all supported scaffolds are a safer practice.

The single-point or two-point suspended scaffold has special requirements with overhead protection or additional platform levels, such as a “double-decker” suspended scaffold (See 1926.451(g)(3)).  In this case, if a worker was using the standard PFAS attached to a vertical lifeline, and if the scaffold suspension line failed, the worker could be injured by the overhead protection or upper platform as it fell.  In fact, the workers’ PFAS might fail completely.

Consequently, the scaffold should be equipped with additional independent support lines equal in strength to the original lines and attached to a separate anchorage, giving the scaffold a fall protection system of its own. In addition, the workers under the overhead protection or additional platform are prohibited from using a PFAS attached to a vertical lifeline system, and instead must attach to the scaffold itself. If a horizontal lifeline system is installed on the scaffold, the horizontal lifeline may be attached to structural members of the scaffold itself, or it may be looped around both the suspension and the independent suspension line above the brake and hoist, but must also be attached to the scaffold itself (not just the support lines).

A type of scaffold where both a guardrail system and PFAS are recommended, but not required, is a “tank builder” scaffold. This scaffold has triangular steel brackets that attach to clips welded to the tank during tank erection. On this particular type of scaffold, the regulation permits the use of standard guardrails; however, if there is a failure of the clip and subsequent bracket, the guardrails will not prevent a fall. On the other hand, if a PFAS system was attached to the tank separate from the bracket, a fall would be prevented in the event of clip/bracket failure.

Learn more about the OSHA regulation on scaffold and fall protection requirements at OSHA.gov.

Fall Protection Regulations Applicable to Scaffolds

  • 1926 and 1910 standards are where OSHA scaffold regulations are found.
  • 29CFR1926 Subpart L governs most scaffolds. This standard applies anytime a “construction type activity” is to be performed from the scaffold. (Proposed changes to the 29CFR1910 Subpart D section will basically eliminate the scaffold section from 1910 and incorporate the 1926 as the sole scaffold standard).
  • 1926 Subpart M covers the use of a personal fall arrest system.
  • 1910.66 is the application regulation for permanent installation (PI) scaffolds, and is only applicable to permanent installations, not to temporary suspended scaffolds.
  • ANSI (A10.8) publishes non-mandatory standards.
  • CAN/CSA-S269.2-M87 governs scaffolds and other standards in Canada.
  • The BSEN series (BSEN12811 parts one through three), are the British and European standards.