Scaffolding Industry - September 2008 - (Page 11) Technically Speaking Each “paragraph” may also have “subsections” instead of a single standard. Another way of looking at this is that a standard may have additional information, making the standard a “subsection.” This is where the roman numerals and letters come into play. In our electrical example, 29 CFR 1926.405(j)(4)(ii)(C), the 4 is the standard while the “ii” and the “C” are additional pieces of information for that specific standard number 4. (You cannot take the information in “ii” and “C” and apply it to another standard. It is only applicable to standard number 4.) So what does this all mean? It means that the OSHA standards are systematic in their arrangement. If you told me that I was in violation of 29 CFR 1926.451(a)(6) I would immediately know that you are talking about the requirement that all scaffolds shall be designed by a qualified person and built according to that design. On the other hand, if you told me my scaffold was in violation of 29 CFR 1926.405(j)(4)(ii)(C), I would have to tell you that you are mistaken since those are standards addressing electrical hazards. In summary, the system works like this: If the standard is 29 CFR 1926.451(d)(12)(v), the “29” and the “CFR” tell us that we are dealing with federal OSHA standards. The “1926” tells us that it is the construction standards. The “451” tells us that it is the scaffold general requirements. The “d” tells us that it is the criteria for suspension scaffolds. The “12” tells us that it has to do with wire rope clips and, finally, the “v” tells us that “u-bolt clips shall not be used at the point of suspension for any scaffold hoist.” If you are using u-bolts, you are in violation of 29 CFR 1926.451(d)(12)(v). Are you expected to memorize all the standards? Absolutely not. But you can see that if you are working with scaffolds, and somebody tells you that you are in violation of 29 CFR 603(a)(1) you get to ask the www.scaffold.org accuser what the scaffold has to do with pile driving equipment! In other words, if 450 through 454 isn’t in there somewhere, it may be the wrong standard. David H. Glabe, P.E., is president of D.H. Glabe & Associates Inc. of Denver. Glabe also serves as the SIA’s liaison to OSHA. E-mail him at dhg@glabe.com. Scaffold Industry SEPTEMBER 2008 9 http://www.scaffold.org
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