Mast Climbing CYA and Documentation

Words: Clint Bridges
Photo: Oranat Taesuwan

The Occupational Health and Safety Administration (OSHA) enforces standards to ensure safe and healthful working conditions for workers. Ever wonder where they get these standards? One resource is the American National Standards Institute (ANSI). When it comes to Mast Climbing Work Platforms (MCWPs), and scaffolds, OSHA is just the tip of the iceberg. The mass below that tip includes institutes like ANSI and the experts that support it.

Why do we care about ANSI? What does it have to do with maintenance? By adhering to the guidelines set by ANSI, you will meet the requirements to properly maintain your equipment and keep your employees safe and productive.

How many times do I hear that OSHA doesn’t know what it’s talking about? This is obviously not the case. While they may not know the workings of each manufacturer in great detail, they do know what’s important. When I talk to OSHA employees, I am amazed at the amount of knowledge they have and impressed with their level of training. Even with newer employees, it is remarkable how much they learn and the experience they achieve in a short amount of time. As a manufacturer, we also appreciate when they contact us to clarify something they are unsure of. OSHA is a vital piece of the construction puzzle to keeping workers safe and injury-free.

While OSHA does a great job of “ensuring safe and healthful working conditions,” it does not give much guidance for maintaining mast climbers (or scaffolds). This is where the ANSI standards can be a great tool for guidance in keeping a properly maintained fleet.

What is ANSI? According to their website, ANSI is a “private, non-profit organization that administers and coordinates the U.S. voluntary standards and conformity assessment system…ANSI represents the interests of more than 270,000 companies and organizations and 30 million professionals worldwide.” One thing is for sure, it represents people who know what they are doing: the developers, manufacturers, and users. Basically, ANSI adopts the standards developed by professionals (adhering to the requirements of ANSI is not easy and is a full-time job for someone who is an expert in this field).

The organization accredited with developing the standards for mast climbers (and many other access products including scaffolding) is the Scaffold and Access Industry Association (SAIA). This standard is A92.9-2023.

How is this all related? The SAIA develops the standard. ANSI adopts the standard. OSHA uses and references the standard to develop and enforce their own standards. Therefore, the SAIA and associations like it have a tremendous effect on the day-to-day operations of a construction site.

Sidenote: Why are more contractors not involved with the SAIA? You can join these committees and have a powerful voice in the standards and use of your equipment. For more information, visit https://www.saiaonline.org/benefits.

A92.9 is the ANSI standard that addresses the responsibilities of the stakeholders of mast climbers from design to sales/rental to end users. This article is going to focus on the responsibilities of the Owner. There was so much that I plan to write an article on the responsibilities of the User, Operator, and Lessor. ANSI definitions for each:
  • Owner: A person or entity who has possession of a MCWP by virtue of proof of purchase or legal possession of a MCWP.
  • User: A person or entity that has care, custody, and control of the MCWP. This person or entity may also be the employee of the operator, a dealer, owner, lessor, lessee, broker, or the operator.
  • Operator: An authorized person qualified to control the movement of a MCWP.
  • Lessor: A person(s) or entity who leases, rents, loans, or otherwise provides a MCWP to another party for the beneficial use of that party (the user). A lessor may also be a dealer, owner, lessee, user, or operator.
If you are one of these, then the requirements of ANSI A92.9 apply to you. Obviously, many of these overlap. Many Owners are Users as well.

The responsibilities of the Owner are under A92.9.7.4.

7.4.1 Basic Principles Sound principles of safety, training, inspection, erection, maintenance, application, and operation consistent with all data available regarding the parameters of intended use and expected environment shall be applied in the performance of the responsibilities of owners with due consideration of knowledge that the unit will be carrying personnel.

The responsibilities of the Owner include maintaining the operating and maintenance manuals. This seems simple, but I would wager that the majority do not skim the manuals, much less read them. Many questions that are asked or errors in the installation and use are in bold letters in the manual. “We’ve been doing it that way for 30 years” does not supersede the manual. Manuals must be kept with the MCWPs when in use.

Owners shall arrange for the specified maintenance to be performed when required by a qualified person. According to the ANSI definition, a qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project. This person must be trained to work on the specific make and model. All manufacturers are different, and having training for one manufacturer does not make you qualified for other manufacturers.

Frequent inspections shall be performed on MCWPs that have been in service for three months or have been out of service for three months prior to being used. If it has been on the job for three months or has been sitting for more than three months, an inspection shall be done before continuing use.

A qualified person (there’s that term again!) on the specific make and model of the MCWP shall perform the inspection. The inspection shall be done according to the manufacturer and include the following:
  1. All functions and their controls for speed(s), smoothness, and limits of motion.
  2. Emergency lowering means.
  3. All chain and cable mechanisms for adjustment and worn or damaged parts.
  4. All emergency and safety devices.
  5. Lubrication of all moving parts, as specified by the manufacturer.
  6. Visual inspection of structural components and other critical components such as fasteners, pins, shafts, locking devices, bolts, nuts, and tie assemblies.
  7. Placards, warnings, and control markings.
  8. Items specified by the manufacturer.
  9. Correction of all malfunctions and problems identified and further inspection if necessary before continuing use.
In addition to frequent inspections, annual inspections must be performed no later than thirteen months from the date of the prior annual inspection.

Replacement parts shall be identical or superior to the original MCWP parts or components. Many people are unaware that you do not have to use OEM parts or components. While, as a manufacturer, we would love for you to buy them from us, a main focus in the design of EZ Scaffold products is to use parts that are available off the shelf for the convenience of our customers. That being said, buying parts from the original manufacturer ensures that the requirements are met and reduces the owner’s liability if a part fails.

Owners shall make sure that all maintenance personnel and operators are trained. It is vital that the training is product-specific. Most, if not all, of the MCWP manufacturers provide excellent training. Take advantage of it by training your KEY personnel. I can’t count how many times I have provided new product training to someone who was just hired yesterday and will not be there tomorrow.

Owners shall also provide the proper information to the users and operators. This should come from the manufacturer. If the manufacturer is not available, a qualified person or equivalent entity may be used.

Modifications and Record Retention Documentation is probably the most tedious responsibility but, when it comes to liability, can be the most important responsibility of the owner. If you don’t document it, it didn’t happen. Also, it must be legitimate with documented pass/fails and corrective action taken.

7.4.13.1 - The owner shall retain the following records for at least three years:
  1. Name and addresses of the subsequent purchaser of each MCWP by serial number and date of delivery.
  2. Records of the person(s) trained upon each delivery of a MCWP.
  3. Name(s) of personnel providing training.
  4. Names of person(s) receiving familiarization upon delivery, unless the individual has been provided with familiarization on the same model, or one having characteristics consistent with the one being delivered, within the prior ninety (90) days.
  5. Name of person(s) providing familiarization upon delivery.
  6. Written records of the FREQUENT and ANNUAL INSPECTIONS shall be kept by the owner when they perform the inspection. The record shall include deficiencies found, corrective actions, and identification of the person(s) performing the inspection and repairs.
  7. Records of the pre-delivery inspection performed prior to each delivery.
All trainees should have evidence of training including their name, the entity providing training, the name of the trainer, identification of training including type and clearly stating that it covered MCWPs, and date of training.

Modifications shall only be made with the prior written (if you didn’t get it in writing, it didn’t happen, just like getting paid on a change order!) permission of the manufacturer. If manufacturer approval cannot be obtained or is not obtained in a reasonable amount of time, the permission to perform modifications or alterations may be granted by a qualified person(s) or equivalent entity that is aware and complies with the requirements of this Standard and considers the manufacturer’s operator manual.

Owners shall comply with all safety bulletins received from the manufacturer or dealer.

If you sell your MCWP, you shall provide the operating, maintenance, and parts manuals to the new owner and offer training or advise where training may reasonably be obtained. PLEASE PLEASE PLEASE make sure the new owners have access to training. I appreciate it when the previous owner calls me to let me know the contact information of the new owner. It amazes me that people will use something that can cause death or injury with little or no training.

The part of 7.4.1 that stands out to me is the phrase "DUE CONSIDERATION THAT THE UNIT WILL BE CARRYING PERSONNEL." We get so busy with the task at hand, getting units in the wall, etc., that it is easy to overlook the seriousness of our responsibility to our employees on the job site. It has been my experience that scaffold is given very little thought about inspection and maintenance. Hence, the need for standards like ANSI A92.9. Its adoption and use will dramatically improve the safe use of Mast Climbing Work Platforms and protect the liability of the owners/users.
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