Letters of Interpretation

OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Each letter constitutes OSHA's interpretation of the requirements discussed.

Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information.

These letters of interpretation and the standards they address may not apply to OSHA State Plans. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or additional requirements. Please see OSHA-approved State Plans for more information.

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Date Title Standard Number
Storage of materials that prevents inspection of scaffolds before workshifts; incidental storage amounts that do not inhibit scaffold inspection. 1926.250, 1926.250(b)(5), 1926.451, 1926.451(b)(9), 1926.451(f)(3)
Fall protection requirements for an employee working from a ladder on a walking/working surface other than the ground. 1926.500, 1926.500(a)(2)(vii), 1926.500(b), 1926.501, 1926.501(b)(1), 1926.1050, 1926.1052, 1926.1053, 1926.1060
Compliance of Non-Stop base tower and extension frames with scaffold access requirements. 1926.451, 1926.451(e)(6)(ii), 1926.451(e)(6)(vi), 1926.451(e)(7)
Compliance of Master Plank scaffold planking with OSHA plank strength requirements. 1926.451, 1926.451(a), 1926.451(a)(1), 1926.451(a)(6), 1926.451(f), 1926.451(f)(16)
Fall protection requirements for employees working from a "work bridge" in concrete construction work 1926.450(b), 1926.451(g), 1926.451(g)(4)(ii), 1926.701(b)
Use of aerial lift or scissor lift guardrails as a work or scaffold platform. 1926.450, 1926.502(d), 1926.451(b), 1926.451(b)(2)(ii), 1926.453(b)(2)(iv), 1926.451(a)(1), 1926.451(a)(6), 1926.451(f), 1926.502(d)(23), 1926.451(g)(1), 1926.452(w)
Electrical standard requirements concerning covers for electrical pull boxes, junction boxes, and fittings. 1926.405, 1926.405(b)(2), 1926.405(b)(3), 1926.405(b)(3)(ii), 1926.405(j)(1)(i)
Clarification of 1926.451(a)(6) requirements for scaffolds and bridge-painting projects. 1926.451(a)(6), 1926.451(a)(1), 1926.451(a)(3), 1926.451(d)(12)(iv), 1926.451(f)(16), 1926.451(g)(1)(i), 1926.451(g)(1)(ii), 1926.451(g)(1)(iii), 1926.451(g)(1)(iv), 1926.451(g)(1)(v), 1926.451(g)(1)(vi), 1926.451(f)(13), 1926.451(g)(1)(vii)
Use of mobile scaffolds with casters in the unlocked position; moving the mobile scaffold without dismounting. 1926.452(w)(2), 1926.452(w)(3), 1926.452(w)(6)(iv), 1926.452(w)(6), 1926.452(w)(6)(i), 1926.451(f)(1), 1926.451(a)(1)
Safety Standards regulating the stability of mobile scaffolds, scissor lifts, and aerial work platforms. 1926.452(w), 1926.453, 1926.452(w)(6), 1926.452(w)(5), 1926.453(b)(2)(viii), 1926.453(a)(1), 1926.453(a)(2)
OSHA Guidance concerning use of clip on products for ladders to facilitate transport of the ladder or other objects. 1926.1053(b)(4), 1926.1053(b)(3), 1910.23
Fall protection requirements for roofing work in residential construction versus roofing work in other areas of construction. 1926.500, 1926.501, 1926.502, 1926.503
Planking, safety line, and personal fall arrest system requirements for tank builder's scaffolding. 1926.451, 1926.451(b), 1926.451(b)(1), 1926.451(b)(1)(i), 1926.451(b)(2), 1926.451(b)(2)(i), 1926.451(b)(2)(ii), 1926.451(b)(3), 1926.451(b)(3)(i), 1926.451(b)(3)(ii), 1926.450, 1926.452, 1926.453, 1926.454
Non-Stop Scaffolding Inc.'s scaffold towers do not comply with OSHA's integral prefabricated scaffold access frame or ladder/stairway type access requirements. 1926.451, 1926.451(e), 1926.451(e)(6), 1926.451(e)(6)(i), 1926.451(e)(6)(ii), 1926.451(e)(6)(iv), 1926.451(e)(6)(vi), 1926.451(e)(7)
Request that OSHA adopt a requirement that all scaffold planks meet a "scaffold grade" under recognized grading rules. 1926.451, 1926.451(a)(1), 1926.451(a)(6), 1926.451(b), 1926.451(a)
Clarification of requirements for construction scaffold erection/dismantling; safe means of access; blocks for two-point suspension scaffolds. 1926.451, 1926.451(a)(3), 1926.451(a)(4), 1926.451(b)(1), 1926.451(b)(1)(i), 1926.451(c)(1)(iii), 1926.451(d)(16), 1926.451(d)(17), 1926.451(f)(3), 1926.451(e), 1926.451(e)(9)(i), 1926.451(e)(9)(ii), 1926.451(e)(9)(iii), 1926.451(e)(9)(iv), 1926.451(g)(1), 1926.452(p)(3), 1926.1431
Exemptions for installation of guardrails on wall (interior) side. 1926.451, 1926.452, 1926.453, 1926.454, 1926.451(g), 1926.451(g)(4)(i), 1926.451(b)(3), 1926.451(g)(1)(iv), 1926.451(g)(2), 1926.450
Ladder-access gates in scaffold configuration. 1915.71(k), 1926.451(e)
Applicable standards to lifting personnel on a platform supported by a rough-terrain forklift. 1926.451, 1926.451(a)(1), 1926.451(a)(6), 1926.451(c)(2)(iv), 1926.451(c)(2)(v), 1926.452, 1926.453, 1926.454, 1926.602, 1926.602(c), 1926.602(c)(1)(vi), 1926.602(c)(1)(viii), 1926.602(d)
Acceptability of the Pin-Lok scaffold plank product. 1926.451