The requirement for the installation of construction personnel hoists (CPH) has long been a controversial and confusing standard. As recently reported in the Cal-OSHA Reporter the Appeals Board has issued conflicting opinions on appeals over the past 20 years specifically regarding when the hoist must first be installed and whether the uppermost floor would include the roof. It appears that Cal/OSHA has filed a request with Standards Board to revise and clarify the rules. Construction Safety Order §1630 requires employers to install and operate CPHs during construction of buildings which are 60 feet high or 48 feet deep. The primary purpose of the hoist is to reduce the amount of climbing for workers and provide easier access for medical emergencies. Cal/OSHA intends to reduce the ambiguity by clarifying the wording so that 1) elevator landings are provided when the height or depth of the building or structure reaches 36 feet; 2) elevator access must be provided so that workers are able to travel to a landing from any point in the building within 5 minutes; and 3) a roof is an upper-most floor.
I have found this standard very difficult to apply. Part of the controversy is when does the 60 foot threshold apply? Cal/OSHA had maintained that the uppermost floor of a structure is the roof. However, the standard states that the building or structure height “shall be determined by measuring from ground level to the highest structural level including the parapet walls, mechanical rooms, stair towers and elevator penthouse structures but excluding antennas, smoke stacks, flag poles and other similar attachments.” Cal/OSHA is proposing to specifically add the verbiage, “for the purpose of this section a roof is an uppermost floor”. I find this revision still confusing. If the roof is the upper most floor, why continue to include parapet walls, mechanical room, penthouse structures, etc. as part of the determination of whether a building is more than 60 feet? I have seen several situations where the roof itself is less than 60 feet, but the addition of the parapet wall or structure of the roof brings the total height to more than 60 feet.
In addition, the standard currently states that “at work locations where unusual site conditions and structure configurations exist, alternate means of access…shall permitted.” Unusual site conditions include bridges, steel tank erection, water towers, cooling towers, etc. However, there is no current provisions for unusual site conditions such as small property foot print, remodeling of existing buildings, or when building facades are present.
Alternate means of access include, personnel platforms (as specified in §5004) and suspended power-driven scaffolds. However, §5004 states that the use of crane or derrick on a personnel platform is prohibited except when the erection, use and dismantling of conventional means of reaching worksites, such as stairway, elevating work platform or scaffold “…would be more hazardous or is not possible because of structural design or worksite conditions”. So if the structure contains conventional means of access/egress such as stairways why would personnel platforms be required? I have seen situations where the CPH is not practical and Cal/OSHA has requested a personnel platform be used, even in situations where two building stairways that provide access and egress are in place. In my opinion the personnel platform, assuming it could be used at all due to the height requirement (60 feet) is more hazardous than the available stairways. I would like to see more clarity in the standard for those situations where construction personnel hoist is not practical.