MACOSH RECOMMANDATIONS ON 1915 SUBPART E

July 14, 2010

The MACOSH committee has reviewed 1915 Subpart E, entitled Scaffolding,
Ladders and Other Working Surfaces. While Subpart E mainly covers
scaffolding and ladders it also includes sections on lifting personnel
in work platforms, directions on confined space access and working
surfaces which include life jacket requirements. This regulation has
been in effect for many years and needs to be reviewed and updated to
include modern shipyard construction practices.

The section on staging and scaffolds under 1915.71 outlines the general
requirements for construction and design of these structures. However,
some of these structures are rarely used and have been replaced with
newer styles such as tube and coupler. While some of the larger
shipyards no longer use the staging styles in the regulations the agency
must consider that there may still be smaller yards throughout the
country which may still use some of the of staging/scaffold listed in
this section. Therefore, the regulations on these types of staging may
still be necessary. For newer styles of staging the regulations allow
the industry to follow manufacturer recommendations to construct staging
which is not listed in the standard. This practice is acceptable to
industry however; it may become an enforcement problem for the agency
and should be reviewed. 

The agency should also not rely on construction industry standards for
scaffolding and staging regulations for the maritime shipbuilding and
repair industry. While the industries share many common practices there
are also some unique practices found in maritime industries. The need to
stage tanks and confined spaces where the staging is used for both a
working platform and material storage platform along with unique support
methods is one example. 

One section in 1915.71, specifically 1915.71(b)(10,) provides
regulations for lifting personnel by crane. The practice of lifting
personnel by crane is rarely used as this method has been largely
replaced by powered mobile man lifts. If this section is to remain in
the standard the committee recommends that this be revised to either
provide more detail or for it to be removed and inserted in another
section. The committee is concerned that this section could be removed
and instead referenced in 1926.550(g). The committee does not recommend
this approach as the use of cranes in shipyards is much different than
general or construction industry practices. The shipyard industry should
have their own regulation and the agency should not fall back
referencing other industry standards.

If the agency decides to update subpart E it should also review the five
foot rule found in (1915.77(c)). There exists a great deal of confusion
on this regulation even though it may appear to straightforward. The
height requirement for fall protection differs in the construction and
general industry regulations versus the maritime standard. Confusion
exists both from an employer and enforcement standpoint.

 The maritime industry has used the five foot regulation for many years
and has made decisions and has built structures to meet this
requirement. Changing this to a four foot rule is not recommended by
MACOSH. However, work within the shipyard done by shipyard employees may
not always be clearly related to shipbuilding and repair. Evidence of
this was provided in the Related Employment document submitted
previously to the agency. So, if a shipyard employee is working on a
project not directly related to shipbuilding/repair they should not be
required to make a determination on whether to implement a four or five
foot fall protection rule. One rule should apply to all maritime
employees.   

Additionally, the MACOSH committee suggests that the agency take an
overall look at subpart E and consider moving some sections to other
parts of the standard or making the section on Working Surfaces a stand
alone section. As an example, the requirement for a worker to wear a
harness when working above five feet when not protected by staging
(1915.77(c) seems to be a better fit in Subpart I where there is an
extensive discussion of fall protection devices and requirements. 

Section 1915.76(b) on confined spaces also seems out of place in this
section and seems to be a better fit in subpart B. 

The difficulty of relying on construction and general industry standards
to regulate the maritime industry is shown in the attachment that
follows. The following staging installation checklist is used by one of
the major shipyards in the country to ensure both that the staging it is
erecting is constructed properly for safety and also meets the
regulatory requirements. The checklist references the different sections
of staging regulations (where applicable) to ensure compliance. This is
an example of the difficulty encountered when trying to comply with this
section of the standard to ensure that all of the regulations are
followed. It also illustrates the need to have an encompassing maritime
standard in the regulations.

 The industry would be better served to have its regulations for
scaffolding and ladders listed in the maritime section of the standard
instead of looking at other industry standards for guidance. The MACOSH
committee recommends that the agency review and update subpart E to
provide a workable, unified and encompassing standard for the maritime
industry. 

Attachment 1

NO.	

ATTRIBUTE	

COMMENTS

1	All lumber and plywood is fire retardant and marked accordingly as FR
or FR-X	Safety Manual 

2	All 2x6 and 2x4 lumber to be SPF (spruce-pine-fir) 

grade MSR 2100f-1.8E or better	Stage Building Lesson Plan 

3	If scaffold components of different manufactures are used, they fit
together without force and a competent person has determined that they
are safe for use.	SIA Code of Safe Practices II.L

1926.451(b)(10)

4	No unstable objects such as barrels, boxes, cans, etc. are being used
for supports of working platforms 	OSHA 1915.71(b)(6)

OSHA 1910.28(a)(2)

5	All metal components are in good condition and are not cracked,
corroded, bent, dented, sand blasted (which thins tube walls) or
otherwise defective.	OSHA 1915.71(b)(5), (d)(1)

6	All wood components are free of rot, large loose knots, cross grain,
shakes, splits, burns or other damage and opaque paint. 	OSHA
1915.71(b)(4),(5)

Safety Manual 

OSHA 1926.451(b)(9)

7	All metal scaffolds are properly grounded.	Stage Builders Construction
Guide Book Page 14

Stage Building Lesson Plan 

8	All clamp type couplers are properly size for the pipe they are
attached to. Use rubber or other makeshift material to increase pipe
diameter is prohibited.	



9	All clamp type tube couplers have been installed with a minimum 40
ft-lbs of torque. Fully tightening the un-lubricated bolt with a 12 inch
long wrench 3/4 turns past the snug tight condition satisfies this
requirement. 	Purdue Univ. Scaffolding Course



10	The scaffold has been erected, altered, or dismantled by personnel
trained by the applicable EB Stage Building course and only under the
supervision of a competent person.	OSHA 1915.71(b)(7)

11	Staging that cannot be erected, modified, or loaded in accordance
with this checklist has been approved by engineering.



	12	Point loads in excess of 25 pounds are properly distributed over the
width of steel planks with wood blocking.	Slotted planks for Swiss Fab
Scaffolding Pittsburg Testing Lab Report No. 871088

13	All wood used for planking to be laminated and marked as proof
tested.	Safety Manual 

14	All 2 x 12 Microllam planks are supported at spans less than 10 feet.
Trus Joist McMillan Scaffold Plank Application Guide No. 3060 for fully
saturated conditions

15	All 2-1/2 x 12 Microllam planks are supported at spans less than 14
feet.	Trus Joist McMillan Scaffold Plank Application Guide No. 3060 for
fully saturated conditions

16	Platforms are at least 20” wide except in such areas that the
structure of the ship makes it impossible to provide this width.	OSHA
1915.71(i)(2)

17	Openings covered by ¾” plywood are less than 18 inches wide.	AN
3099

18	Open sides of scaffolds are less than 12 inches from the work face as
measured normal to the work face to the edge of the platform.	Stage
Builders Handbook



19	Platform planks are laid with their edges close together so the
platform will be tight with no spaces through which tools or material
will fall.	1910.28(b)(11)



20	Platform units are cleated, restrained by hooks or equivalent means,
or extending over the centerline of their supports by at least 6 inches
and not more than 12 inches.	OSHA 1915.71(i)(3)



21	Abutted planks are resting on separate support surfaces and secured
from slipping off of the support. This provision does not preclude the
use of common support members such as “T” sections or hook on planks
designed to rest on common supports.	1910.28(b)(12)

22	Where planks are overlapped, they are lapped over the supports.
Planks are overlapped at least 12 inches, or nailed together, or
otherwise secured.	1910.28(a)(11)

23	Planks that rest on the bearer at other than a 90-degree angle are
laid first.	1910.28(b)(13)

24	The top and bottom surfaces of the plank are visible and free from
paint and other opaque finishes.	1926.451(b)(9)



25	Wood planking that has been notched has been approved by engineering.
Trus Joist McMillan Scaffold Plank Application Guide No. 3060 Cautions

26	Freestanding scaffolds conform to the 4 to 1 height-to-base ratio
requirement.	SIA Code of Safe Practices II.F



27	Scaffolds that do not meet the 4-to-1 height to base ratio are
secured to the structure by the use of ties (to include ties, guying,
bracing or equivalent means).	SIA Code of Safe Practices II.F

1926.451(c)

28	The tie has been installed at a height less than 4 times the minimum
base dimension and has been installed at a horizontal member that
supports the inner and outer legs and.	SIA Code of Safe Practices II.E

1926.451(c)(1)(iii)

1926.451(c)(1)(I) 

29	Ties have been repeated every 20 feet or less vertically for
scaffolds that are 3 feet or less in width.	1926.451(c)(1)(ii)

30	Ties have been repeated every 26 feet or less vertically for
scaffolds wider than 3 feet.	1910.28(c)(13)

1926.451(c)(1)(ii)

31	The vertical distance from the top tie to the top of the scaffold is
less than 4 to 1 minimum base dimension.	1926.451(c)(1)(ii)

32	Ties are installed at each end of the scaffold and at horizontal
distances not to exceed 30 feet.	1910.28(c)(13)

1926.451(c)(1)(ii)

33	Ties resist movement of the scaffold both towards and away from the
work surface, i.e. both pulling and pushing forces.

	34	Vertical diagonal bracing is installed where feasible.

	35	All vertical poles are supported laterally by horizontals in two
directions at least every 6.5 feet.

	36	The bottom ends of all vertical metal poles are supported on a
suitable base plate/jackscrew unless it bears directly on a metal
surface.	1915.71(d)(4)

43	Rest platforms are installed no more than 35 feet apart vertically
for ladder access.	1926.451(e)(2)(iii)

44	Each scaffold stairway is at least 18-inches wide between stair
rails.	1926.451(e)(4)(ix)

45	Stairways are installed between 40 and 60 degrees from the
horizontal.	1926.451(e)(4)(xi)

46	Riser height and tread depth are uniform to within a ¼-inch except
that the riser height may vary more than this amount for the top and
bottom steps for the entire system but not each flight of stairs.
1926.451(e)(4)(xiii)-(xiv)

47	Handrails and toprails serving as a handrail provide an adequate
handhold for grasping to avoid falling. 	1926.451(e)(4)(iii)

48	Handrails and toprails that are used as handrail are at least 3
inches from other objects.	1926.451(e)(vi)

49	Stair rails are 36-inches from the upper surface of the stair rail to
the surface of the tread, in line with the face of the riser at the
forward edge of the tread.	OSHA 1915.71(k)(2)

1926.451(e)(4)(vii)

50	Stair rails (consisting of a of a top rail and a midrail) are
provided on each side of a scaffold stairway.	1926.451(e)(4)(I)

51	Ladders are constructed in accordance with OSHA 1915.72. Ladders made
by the D252 Joiner Shop satisfy this requirement.	1915.72

52	Portable ladders have been secured from being displaced at the top
and bottom. Lashing with fiber rope is prohibited.	Safety Manual 

53	Side rails extend above the level being accessed at least 36 inches
unless grab rails have been provided.	1915.72(a)(3)

54	Ladder is placed at an angle where the horizontal distance from the
top support to the foot of the ladder is approximately ¼ of the ladder
length.	Safety Manual 

1926.1053(b)(5)(I)

55	The bottom rung is less than 24 inches above the supporting surface.
1926.451(e)(2)(ii)

56	Portable ladders exceeding 16 feet in length or any length ladder
used in a dangerous area are equipped with a side rail.	Safety Manual 

57	Metal portable ladders are not used inside the ship (except for LET
access)	Safety Manual

58	Jacobs ladders have either a double rung or a flat tread.	OSHA
1915.74(d)(1)

59	The minimum perpendicular distance between the centerline of the
rungs and any obstruction on the climbing side of the ladder is 30
inches. This distance may be reduced to 24-inches provided a deflection
device is installed to guide personnel around the obstruction.
1926.1053(a)(14)-(15)

applies to fixed ladders 

only

60	There is at least 7 inches of toe kick space between the ladder rung
and adjacent structure.	1926.1053(a)(13)

applies to fixed ladders 

only

61	Scaffolds and components are not loaded beyond their rated
capacities. Wood planks that deflect more than 1/60 of their span are
overloaded.	1926.451(f)(1)

1926.451(f)(16)

62	Ladders are not used to increase the working height of a scaffold
unless positioned so as not to tip the scaffold and/or shift the
platform unless measures have been taken to resist the outward thrust.
The ladder legs do not point load metal planks.	1926.451(f)(15)(I)-(iv)

63	Face the ladder when climbing up or down. 	1926.1053(b)(20)

64	Any damaged part of the scaffold has been repaired, replaced, braced
or moved as required.	1926.451(f)(4)

65	Guardrails are free of energized power cables.

	66	Services (wiring, hoses, etc.) are not supported on guardrails

	67	Employees are not working on scaffolds during high winds.
1910.28(a)(18)

1926.451(f)(12)

68	Scaffolds covered with snow, ice or other slippery material are
prohibited from use until the conditions have been removed. 
1910.28(a)(19)

1915.91(c)

1926.451(8)

69	Side brackets or outriggers are used to support only personnel

	70	Tools, material and debris are removed from scaffold to prevent an
accumulation.	1910.28(a)(20)

1926.451(f)(13)

71	No makeshift devices are being used to increase the working level
height.	1926.451(f)(14)

72	Employees are not on mobile scaffolds when moved.	1926.452(w)(6)

73	Employees working/walking on platforms at a height greater than 5
feet off of a solid surface or at any height above water are protected
from falling to the ground or water either by guardrails or a PFAS. 
1915.71(j)(1)

Safety Manual

74	A fall restraint system is an acceptable alternative to guardrails or
PFAS.	OSHA ltr dated 11/2/95 

from R.Gurnham

75	Guardrails and mid rails are installed on all open sides and open
ends of the platform except where the structure prevents their use.
1915.71(j)(3)

1926.451(g)(4)(ii)



76	Guardrails/chains, swing gates are installed around openings in the
platforms for ladders.	Safety Manual

77	Where open sides of scaffolds are more than 12 inches from the work
face, guardrails are installed or PFAS are used by employees.	Safety
Manual

78	Guardrails are installed at 42 to 45 inches in height.	1915.71(j)(1)



79	Top handrails for stairways are located such that the top surface is
36 inches above the leading edge of the step.	OSHA 1915.71(k)(2)



80	Guardrails are made of wood, pipe, structural steel or minimum ¼”
wire rope. Fiber rope rails are prohibited where exposed to hot work.
OSHA 1915.71(j)(2)



81	Steel or plastic banding is not used as a guardrail however steel
banding may be used to connect the guardrails to the posts.
1926.451(g)(4)(xiii)

82	The entire guardrail system is capable of withstanding a 200 pound
load applied in any direction along the top rail. Rails made of 2x4
lumber spanning no more than 8 feet meet this requirement.	OSHA
1915.71(j)(2)

1926.451(g)(4)(vii)

83	Toeboards have been installed to prevent falling objects in areas
where personnel can pass underneath the platform or equipment or
machinery can be damaged or the area underneath the scaffold has been
barricaded to prevent access.	1926.451(h)(2)(I)

84	Screens have been installed where required to protect employees from
falling objects.	1910.28(a)(17)

1926.451(h)

85	Toeboards are at least 3-1/2 inches in height.	1915.71(j)(5),
1915.71(a)(3)

1926.451(h)(4)(ii)

86	The bottom edge of the toeboard not more than ¼ inch above the
platform. 	Stage Builders Construction Guide Book Page 20

1926.451(h)(4)(ii)

87	All coupling pin snap buttons for the verticals are fully expanded
and engaged.

	88	All telescoping braces have hitch pins with clips installed.

	89	All locking devices i.e. triggers for the connectors are fully
engaged with the vertical pole cups.	



90	The bolt for the trigger mechanism is a ¼ inch diameter grade 8
fastener held in place with a locking type nut.

	91	Both legs of the side bracket are backed up either with horizontals
on the opposite side of the vertical pole or a brace running from the
end of the bracket to the vertical pole at the next level horizontal.
Excel Modular Scaffold Technical Manual Page D-1



92	Intermediate adapters are used in pairs and connected together with a
horizontal bar. 	Excel Modular Scaffold Technical Manual Pages K-2

93	Trusses 5 to 10 feet long have one horizontal installed as a side
stabilizer and trusses 12 to 18 feet long have two horizontal bar side
stabilizers installed.	Excel Modular Scaffold Technical Manual Pages
H-1, H-2

94	Telescoping braces are not used as a bearer for planks.	Excel Modular
Scaffold Technical Manual Page B-8

95	The bearers for Excel staging are capable of supporting a minimum
uniform load of 25 pounds per square foot on the platform when they are
used for access or a minimum load of 50 pounds per square foot on the
platform when used for work as specified in the load tables given in
section B-3 and B-4 of the Excel manual for horizontal bars.	Excel
Modular Scaffold Technical Manual

96	Horizontal bars eight feet or greater in length which are used to
support planks are braced. 	Excel Modular Scaffold Technical Manual

97	The maximum span between button-lok brackets is 8-feet	Button-Lok
Stage Bracket System Installation Instruction Handout Page 4

98	Each bracket is locked in place with two stainless steel set screws
torqued to 40 foot-pounds.	Metal Product Specialists Installation
Procedure

Button-Lok Stage Bracket System Installation Instruction Handout Page 4

99	Five consecutive pre-production studs have passed a proof load test
with a torque bridge tool.	Button-Lok Stage Bracket System Installation
Instruction Handout Page 8

100	Each stud used for mounting a bracket has been proof load tested to
10,000 lbs. Each stud successfully passing the test is circled and
marked with TTC, date and badge of the tester.	Metal Product Specialists
Installation Procedure

Button-Lok Stage Bracket System Installation Instruction Handout Page 13

101	Only 5/8-inch diameter 1-1/8-inch long headed studs marked with an
“H” on the head are used. 

	102	Maximum plank span or fore/aft distance between the frame clamps is
10 feet.

	103	Flat bars are not suspended from the center of the bolt securing
the frame clamp.	Stage Builders Construction Guidebook Page 38

104	No more than two levels of staging are suspended from one pair of
frame clamps.	Stage Builders Construction Guidebook Page 46

105	Maximum platform width is 7-feet for double 5-inch channel and
4-feet for single channel bearers.	Stage Builders Construction Guidebook
Pages 45-49

Memo 340/AW/80-322

106	Holes in channels and flat bars are drilled or punched and not flame
cut

	107	All ¾-inch bolts for the frame clamps are tightened to 30 ft-lbs
torque.	Memo 340/AW/80-410

108	Only lead is used for shimming frame clamps

	109	Lead shims for frame clamps are not wrapped in tape	Stage Builders
Construction Guidebook Page 39

Memo 643/PH-48-80

110	Not currently approved for use. 

	116	The legs are cross braced with 2x4’s.	Stage Builders Construction
Guide Book page 42

117	The maximum clear span between legs is 7 feet.	Stage Builders
Construction Guide Book page 42

118	Assembled per OSHA 1910.28 section (c) and table D-14 for medium
duty scaffolds.	OSHA 1910.28(c)

119	The maximum out of plumb angle of the chain is 15 degrees or 18
inches over a vertical distance of 6-feet.

	120	Maximum platform width is 5 feet.

	121	Maximum plank span is 8 feet.

	122	Maximum number of suspended levels is two.

	123	Two points of support are used for each square tube bearer.

	124	A frame clamp or 2-ton padeye supports each chain.

	125	Each level is tied or braced against side sway. 

	126	The bearer is made from 3x4 lumber minimum	1910.28(m)(2)

127	All legs are made from 2x6 lumber minimum	1910.28(m)(2)

128	The center to center spacing of horses does not exceed 8 feet
1910.28(m)

129	The lateral spread of the legs is not less than 1/3 of the height.
1915.71(g)(3)

130	Horizontal cross bracing is attached as close as possible to the
casters to prevent racking.	1926.452(w)

131	Vertical bracing is attached to all four sides of the tower and runs
the full height of the tower.	1926.452(w)

132	Casters are locked from rolling and turning when the scaffold is
used in a stationary manner.	1926.452(w)(2)

133	Forklifts, trucks are not to be used to move mobile scaffolds unless
so designed.	1926.452(w)(4)

134	Manual force used to move the scaffold is applied as close to the
base as possible but not more than five feet above the supporting
surface.	1926.452(w)(3)

135	Cantilevered platforms are not used on mobile scaffolds unless
outrigger frames or equivalent devices are used to insure stability.
1926.452(w)(7)

136	Scaffolds are stabilized to prevent tipping during movement.
1926.452(w)(5)

137	Screw jacks not attached to casters are fully retracted and are held
up with rope, wire or other means.	Swiss Fab (SHT) Scaffolding

138	The extension of the screw jacks attached to casters is less than 12
inches	1926.452(w)

139	Casters are pinned into the frames or adjustment screws.
1926.452(w)(9)

140	The maximum load capacity has been communicated to personnel using
the scaffold.

	141	Wood planks that deflect more than 1/60 of their span are
overloaded.

	142	Side brackets or outriggers are only being used to support
personnel and their light tools, i.e., under 50 pounds total.

	143	Scaffolds enclosed by tarpaulin, plywood or other material have
been approved by engineering as adequate to resist forces due to wind.

	

