By John Kuhnle, Sr. Risk Control Consultant
Multifunctional scaffolding (MFS) has many names, such as baker staging, Perry scaffold, or narrow scaffold. MFS is a commonly used type of supported scaffold in the construction industry. The systems are inexpensive, easy to assemble and adjust, and can be arranged into many configurations. These scaffolds are most commonly constructed with casters at their base, which allow a worker to roll the assembled unit.
Many contractors do not recognize MFS as supported scaffold. Consequently, they underestimate the risk to their company should an incident occur. Improper training, erection, use, and lack of fall protection can lead to costly incidents. Because of the commonality of MFS on jobsites, and the low heights at which they are used, workers can become complacent about safety. Using a unit without guardrails and moving the unit while in an elevated position (also known as “surfing”) are common causes of incidents that stem from their lightweight design, mobility, and low height. Furthermore, an employer may look to applicable regulations when establishing a risk control plan, yet the regulations are minimum standards that cannot address every exposure an employee will face. Therefore, managing MFS use per the regulations is only one part of a successful loss control program.
Narrow Frame Scaffold, OSHA Fact Sheet
Employers are required by regulations to meet minimum standards regarding employee safety. Failure to comply with regulations can result in fines. These fines represent the regulatory risk a company faces. A company can alleviate their exposure to fines by complying with applicable local, state and federal standards.
The second consideration is the risk of a lawsuit stemming from an incident involving the MFS. This exposure is highly variable and depends upon more than regulatory compliance. Furthermore, complying with regulations may not eliminate the risk of an accident. Managing the comprehensive risk of MFS involves a deeper analysis of manufacturer instructions and the hazards associated with the work.
OSHA 1926.451(b) (10) permits the assembly of an MFS using parts from multiple manufacturers if a competent person determines that the structural integrity of the system is maintained. Yet, many manufacturers specifically prohibit mixing parts. In most cases, the manufacturer applies a label to the frame of the unit addressing assembly and has developed instructions. These should govern the process. A fall from an improperly assembled unit could result in a loss where the assembly procedure is questioned. It is best to source MFS components from a single manufacturer and inspect, construct and use the assembly in accordance with the manufacturer’s instructions. If this is not possible, strong inventory controls, inspection, and training procedures should be implemented to help manage the exposure. If parts must be mixed, written guidance from the manufacturer or a professional engineer should be sought out and implemented. Doing so could help maintain the structural integrity of the MFS and, if necessary, defend a claim stemming from mismatched components.
Employers often select MFS because they are light, nimble and roll easily. However, the flexibility of this system is easily abused. Employees can be tempted to pull themselves along and move the scaffolding while still on the scaffolding platform. This improper use is often referred to as “surfing.” OSHA permits “Surfing” under very specific instances1; however, as with mixing parts, most manufacturers specifically prohibit “surfing” or moving an MFS with an employee or materials on the platform. Instructions typically state that casters should be locked at all times when personnel or materials are on the unit. This means that a worker must descend to the floor before relocating the MFS. Incidents that result from “surfing” or falling materials can be difficult to defend if the manufacturer prohibits the practice and the hazards of “surfing” are easily identified.
Height requirements for fall protection vary based on the jurisdiction where one is working. OSHA states a requirement for rails and toe boards at 10 feet, yet serious injuries can occur at much lower heights. Companies should examine the hazards of their work, determine an acceptable level of risk, and establish controls accordingly. Using 10 feet as a standard may not be adequate to protect a worker from injury under certain circumstances.
Management’s approach to inventory control is one of the most important aspects of risk mitigation. Procedures should be established to help ensure that the correct parts are delivered to workers, and that the parts are in good working order. Sourcing all units from one manufacturer can help reduce these challenges. Management must consider that workers will likely assemble and use any equipment with which they are provided.
Develop a training program around the risk and in addition to the regulations. Train warehouse and delivery staff in the needs of the end user and in the manufacturer’s requirements. This will help to establish control early in the process and remove the entire burden from your field staff. Ask the manufacturer for help, and use their materials for training. Do not stray from the manufacturer’s instructions without receiving their documented consent. Ensure that a qualified person continually trains employees on the proper use of the units and in the hazards of their work. Document the training and save the records.
Since an MFS is considered a supported scaffold it must be inspected accordingly. Management must declare a competent person for each site. This person should oversee all aspects of assembly, inspection and usage. Inspection checklists should be developed specifically for an MFS, and inspections completed after assembly and before each shift. The results of the inspections should be conveyed using a tagging system. As an example, a green tag may represent safe for use; yellow may denote special use requirements; and red might represent a unit is out of service. Inspections should include regulatory requirements, manufacturer’s requirements, and pertinent risks of the work.
Inspections should also include an evaluation of the surrounding site conditions. For example, the floor should be level, penetrations should be covered, electrical power sources identified, and site cleanliness addressed. Falls due to changes in elevation (e.g., stairwells, windows, etc.) should be considered when evaluating height requirements.
Multifunctional scaffolds are a flexible and inexpensive tool that, when managed properly, can help to improve productivity. Management must continually monitor the program for disconnects and act if expectations are not met. Employees must be held accountable for their performance and receive documented retraining when corrective action is required. Ultimately, if the correct equipment arrives on the site, the entire team is properly trained, and the general conditions at the site are acceptable, the risk of an accident should be greatly reduced.
At Travelers, we have a vast array of materials on our Risk Control Customer Portal that can help our customers manage their exposures so that they can get their work done safely. For more information, log in to the Risk Control Customer Portal at the top of the page and search “scaffolding” in the Keyword Search.