Dear CFA Members-

In the wake of last year’s decision by OSHA to rescind the rule allowing residential contractors to walk atop concrete walls, I know that many of you have searched for a feasible way to be OSHA compliant and most have found nothing. Could that be because walking atop formwork is the safest way to accomplish the job? I think so.

Last year at the World of Concrete, I searched the aisles for a viable, out-of-the-box solution to address my fall protection dilemma. Finding nothing new, I elected to make a sizable investment in formwork scaffold brackets and certified planks, not just because I wanted to protect myself from hefty OSHA fines, but also because I wanted to protect my workers. For years, I had been concerned about worker safety while walking atop formwork, but felt helpless to change the way things had always been done. Naively, I believed the latest change in OSHA regulations was an opportunity to improve safety for my crews without me having to be the “bad guy”. Unfortunately, that could not have been farther from the truth.

We began utilizing formwork scaffolding for all of our residential work in March 2011, three and a half months before we were required to do so because I didn’t want to change our procedures mid-season. By the first week of June, just shy of when the new regulation was to take effect, I realized there was no way we would ever be OSHA compliant, using this system, as the fixed unit system could not be configured to accommodate the complexity and individuality we were seeing in residential foundations. Furthermore, it had become obvious to me that the workplace was not safer. In fact, I was certain that the number of expensive, back-related worker comp claims would surely increase, if we continued with this system since we had already observed increases in worker fatigue…but what to do?

They say, “timing is everything”, and it was right at that time that I had the fortunate luck of receiving, yet another e-mail from my insurance company, reminding me of the June 16 deadline for implementation of conventional fall protection. Like numerous other emails I had already received, this one had multiple links for additional resources and information, including a link to Appendix E, where I found a sample Alternate Fall Protection Plan (AFPP). I had known that AFPP’s were an option, but only if you could prove infeasibility, not related to financial hardship. Up to this point, I had not even taken the time to investigate Appendix E because I hadn’t believed there was a possible way to prove infeasibility of the formwork scaffold system. However, feeling frustrated and doubting my ability to successfully implement the scaffold system, and knowing there wasn’t anything else out there, I clicked the link to view the sample plan, written by and for the pre-cast concrete industry. I remember thinking to myself, “Let’s just see what makes PCI so special that they don’t have to use conventional fall protection.”

As I read through the PCI AFPP, I discovered that it wasn’t that they were so special but rather they made sensible arguments. In fact, many of the infeasibility arguments they presented as justifications for using an AFPP were arguably relevant to the removable concrete form (RCF) industry, and it was at that moment I realized the CFA had a LOT of work to do.

Immediately, I contacted Jim Baty, and rattling at a hundred miles per hour, told him that I, like many others, believed the use of formwork scaffold systems had been limited, due to financial reasons, but that wasn’t true. “We haven’t been using scaffold systems, because they don’t work to make the job-site safer, and I have proof that this is the case.” With Jim’s editorial assistance, I set out to fashion a feasibility study to document Michel Concrete’s experience with formwork scaffold systems, so that other CFA companies would have access to the same information, without having the same expense, frustration, and exposure to additional work comp claims.

I am pleased to announce, that within this issue of Concrete Facts, the Michel scaffold feasibility study is finally published and available to everyone for use as a resource in developing their own company specific AFPP. I hope you will find it to be a useful tool, and I look forward to working with anyone who needs further assistance.

Working together to improve the industry is what it is all about. I am a proud member of the CFA.