“It is your concern when your neighbor’s wall is on fire.”  — Horace

On November 26, 2025, a fire enveloped a high-rise apartment in the Wang Fuk Court complex that was undergoing significant renovation. The fire killed at least 159 people and took the Hong Kong fire department almost two full days to extinguish.

Hong Kong officials attribute the quick spread of the fire to the contractor’s use of bamboo scaffolding covered with combustible netting and their use of foam insulation panels to cover and protect the building’s windows.

The people of Hong Kong are angry and blame the Hong Kong government for the disaster, which in turn blames the contractors. Talking about the “substandard” construction materials, Eric Chan, Hong Kong’s Chief Secretary, reportedly said, “Contractors skimped to make greater profits.”

We tend to believe that when something terrible happens, that some terrible crime caused it. The more terrible the consequences, the more terrible the crime.

Is that really how it is?

OSHA Regulations

Could this happen here? Are there codes and regulations that prevent U.S. contractors from protecting windows from damage by covering them with panels of polystyrene foam insulation? Are there codes and regulations that prevent U.S. contractors from using bamboo to construct scaffolding and then wrapping them with netting made of combustible fibers?

When it comes to regulations for the U.S. workplace, we turn to OSHA. While the fatalities in the Hong Kong fire were apartment residents, not workers, a similar fire in the United States would still get OSHA’s attention. The scaffolding was, after all, a workplace regulated by the standards in 29 CFR 1926.

Safety Nets — The standard for safety nets in Subpart E, 29 CFR 1926.105, talks about the strength and dimensions of netting, but says nothing about materials of construction, except that “forged steel safety hooks or shackles shall be used to fasten the net to its support.”

Bamboo Scaffolding — OSHA addresses scaffolding in Subpart L, where it has nothing to say about bamboo. OSHA does require, in 29 CFR 1926.451(d)(2), that suspension scaffold outrigger beams “be made of structural metal or equivalent strength material,” and in 29 CFR 1926.451(d)(5)(i) that support devices “be made of steel, wrought iron, or materials of equivalent strength.” The only mention of fire in the scaffolding standard is in 29 CFR 1926.451 (b)(9), where OSHA allows that wood platforms may be coated periodically with fire-retardant finishes, as long as the coating does not obscure the top or bottom wood surfaces, which would make it difficult to detect cracks or other damage to the wood planks.

Although we are unaware of any U.S. scaffolding manufacturers that use bamboo, when a scaffold manufacturer can show that they are using bamboo that is as strong as steel and capable of supporting its own weight plus at least 4 times the maximum intended load, there is nothing in the OSHA regulations that prohibit its use.

Fall Protection — OSHA primarily considers safety nets as part of a fall protection system, rather than as a means to prevent construction debris from falling onto people below, be they workers or passers-by. In Subpart M, OSHA addresses Fall Protection. Specifically, OSHA addresses fall protection systems criteria and practices in 29 CFR 1926.502.

The typical fall protection in construction is a standard guardrail system, with a top rail, midrail, and toe board. In 29 CFR 1926.502(b)(15), OSHA acknowledges that top rails and midrails can be constructed of manila, plastic, or synthetic rope, on the condition that the contractor inspects the rope “as frequently as necessary” to make certain that its strength hasn’t deteriorated.

As for safety net systems, OSHA also addresses them in 29 CFR 1926.502(c). This section addresses strength and dimensions, but has nothing to say about fire-resistance.

NFPA Codes

So, it appears that OSHA regulations do not prohibit U.S. contractors from doing what Chinese contractors did in Hong Kong. What about the codes developed by the National Fire Protection Association?

Two codes get mentioned: NFPA 241 (2022) and NFPA 701 (2023).

NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, does not say anything about where flame-resistant or flame-retardant materials should be used. It is only relevant in this context when other codes, standards, or regulations call for flame-resistance or flame-retardance.

The other code, NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations, seems a more likely candidate to provide direction on fire-resistant scaffolding, netting, and window coverings. Sadly, what it has to say is limited. In §7.7.1, the code says, “Accumulations of unnecessary combustible forms or form lumber shall be prohibited.” Okay. What combustible materials are unnecessary? The appendix offers some non-mandatory advice:

A.7.7  Steel scaffolding or approved fire-retardant lumber and planking should be used on both the outside and inside of the structure. Construction materials (e.g., forms, shoring, bracing, temporary stairways, platforms, tool boxes, plan boxes, solvents, paints, tarpaulins, and similar items) should be of the noncombustible, fire-retardant, safety solvent, or high flash point types, as the case necessitates. A concerted effort should be made to attain as high a level of noncombustibility of materials as possible. [emphasis added]

There we have it. A footnote to a vague requirement. Hindsight being 20/20, we can point to A.7.7 and say, “See. In NFPA 241, A.7.7 would prohibit all of the practices that led to the high-rise fire in Hong Kong. The polystyrene foam window coverings, the bamboo scaffolding, and the combustible netting would all be discouraged.”

Turning Hindsight Into Foresight

There is no virtue in spending more than necessary. We all have a vested interest in good cost control on construction projects. None of us, however, want to see a reoccurrence of the fire in Hong Kong. In our country or anywhere else. If we didn’t recognize the hazard of using combustible materials in the construction of scaffolding, in the protection of glazing, or in fabrication of safety netting, we do now.

So, as with all recognized hazards, let’s act accordingly, and not wait for the codes and regulations to catch up.

Author

  • Mike Schmidt

    With a career in the CPI that began in 1977 with Union Carbide, Mike was profoundly impacted by the 1984 tragedy in Bhopal and has been working on process safety ever since.

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