Recent revisions to section 1637 of Cal-OSHA have given rise to issues pertaining to the compliance of certain LVL scaffold planks. These issues have been brought to the attention of the SAIA Platform Council and a position statement has been deemed warranted in an effort to provide clarification.
In 2010, Cal-OSHA adopted a revision to section 1637 that included the following verbiage in sub-section C.4:
Prior to being placed in service, all laminated veneer lumber scaffold planks, manufactured after December 2, 2010 shall be labeled with the seal of an independent, nationally recognized, inspection agency approved by the International Accreditation Services (IAS) certifying compliance with ASTM D 5456-09a and ANSI/ASSE A10.8-2001, Section 5.2.10.
Note: ASTM D 5456-09a is the standard for the evaluation of structural composite lumber products. ANSI/ASSE A10.8-2001, Section 5.2.10. requires the inspection agency to certify that laminated veneer lumber scaffold planks are compliant with the design criteria in the ANSI/ASSE A10.8 standard.
The intent of this revision was to improve upon requirements for product quality and third-party verification of LVL scaffold planks. The verbiage of this requirement was considered and selected by SAIA, OSHA representatives and other industry experts.
While this requirement is clear for some LVL scaffold planks, it is unclear for LVL scaffold planks that are “produced” by secondary mills who do not themselves produce the LVL. It is the business model of some LVL scaffold plank manufacturers to purchase LVL “candidate stock” as raw material from one or more manufacturers of LVL, and reprocess this LVL candidate stock into scaffold planks. This may include physical processes such as ripping to finished width, cutting to length, proof-testing, easing edges, and embossing sides. This also includes the requirements to establish properties for flat-use in accordance with OSHA capacity and deflection requirements, provide literature traceable to the product reflecting these properties and other manufacturer recommendations on proper use, inspection, etc.
Under the scenario described above, the following questions should be considered in providing adequate material traceability and labeling. For each question, the Plank & Platform Council of the SAIA provides the following recommendations (printed in italics):
- · Which mill numbers are required to trace back an individual scaffold plank to a single mill source?
Mill numbers should be provided as needed to identify the LVL back to a single mill source for both the LVL manufacturer and the scaffold plank manufacturer. In the scenario where a single LVL mill source is utilized, a single mill source claim may be adequate to identify both the LVL manufacturing mill and the scaffold plank manufacturer. In the scenario where multiple LVL mill sources are utilized, it is the opinion of SAIA Platform Counsel that the mill numbers for both the LVL manufacturer and the scaffold plank manufacturer should be identified, to ensure traceability is not compromised.
- · Which third-party seals are required to certify compliance with ASTM D5456 and ANSI A10.8?
Third-party agency seals should be provided as needed to certify compliance with both the requirements of ASTM D5456 and the capacity requirements of ANSI A10.8. In the scenario where a single third-party seal is shown on the plank, this seal indicates the third-party certification of both standards. In other instances where two third-party seals are used (one for the LVL manufacturer, and one for the scaffold plank manufacturer), it should be clearly indicated on the plank and/or literature to which mill each third-party seal pertains. In either case, it is the responsibility of the scaffold plank manufacturer and their third-party certification agency to have contained within their quality management system assurance that all incoming raw materials meet the ASTM D5456 requirements, and that all finished scaffold planks meet the ANSI A10.8 capacity requirements.
- · What additional marks are required to meet the marking and traceability requirements of ASTM D5456 and ANSI A10.8?
No additional marks are required in ANSI A10.8. ASTM D5456 states that finished product marking from the LVL manufacturing facility shall be defined within the Manufacturing Standard approved by the third-party agency. The following marks are typically required for structural LVL products: manufacturer name and/or logo, inspection agency name and/or logo, plant number, production date, product type, and product grade. It is recommended that any LVL manufacturer of candidate stock supplied to a scaffold plank manufacturer include all of these marks on each piece of candidate stock.
- · How are the capacity requirements of ANSI A10.8 met?
Under the scenario where multiple LVL sources and/or grades are used as raw materials for scaffold planks, each should be qualified and evaluated independently against the capacity requirements of ANSI A10.8.
- · Was the LVL produced in North America?
Under any scenario where the scaffold plank manufacturer is procuring LVL from one or more mills from outside of North America, they should not make any claims that the product is manufactured in North America.
- · Is the plank produced under a Quality Management System?
Under any scenario where a Quality Management System does not cover both the manufacture of the LVL and the manufacture of the scaffold plank, no claims should be made regarding the Quality Management System used.
It is important to note that this process can be done correctly and incorrectly for both a single step producer or a two step producer. Just because a product is labeled or claimed to adhere to the mandatory standards does not necessarily mean compliance. It may also be possible to provide traceability of production information without incorporating some of the markings discussed in this document provided that an integrated inventory control and Quality Management System exists between all parties in the supply chain. It is the responsibility of the user to discuss the manufacturer’s quality control and third party audit processes to confirm that the proper steps are being taken to produce safe and compliant plank.
The questions that have been addressed in this position statement have not been covered in any previous documents by the Plank & Platform Council of the SAIA. This council will review their “Engineered Wood Scaffold Plank Purchasing Guidelines” in 2012 and address this topic.
About the SAIA
The Scaffold & Access Industry Association (SAIA) is a non-profit trade 501(c)(6) association committed to raising the standards of professionalism within the scaffold and access industry. The SAIA represents all facets of the scaffold & access industry through various councils that include, aerial work platform, construction hoist, fall protection equipment, international, industrial, mast climbing, plank and platform, supported scaffold and suspended scaffold. Through its various programs, the SAIA promotes safety, training and a highly professional, responsible image of the scaffold and access professional. The SAIA delivers hundreds of safety training programs a year at various locations throughout the world. These programs cover all aspects of scaffold and access safety and equipment use. The SAIA is also the secretariat for the American National Standard, SAIA ASC A92 standards. For more information, call (816) 595.4860 or visit them at www.saiaonline.org.