- Standard Number:
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. This 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. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
April 19, 1977
Mr. Wilson Tanner,
Associate Vice President
Outdoor Advertising Association
of America, Inc.
1660 L. Street, N.W., Suite 215-6
Washington, D.C. 20036
Dear Mr. Tanner:
This is in response to your letter of March 9, 1977, regarding a question on walking surface platforms attached to a billboard. In addition, it confirms your telephone conversation with a member of my staff.
The question posed is "Does OSHA consider walking surface platforms (or decks or catwalks) to be permanent or temporary, or do they consider it nothing at all?" It would be inappropriate for the Occupational Safety and Health Administration (OSHA) to answer this question as presented, due to the connotations that may be involved.
OSHA's general industry scaffolding terms defines a scaffold as any temporary elevated platform and its supporting structure used for supporting workmen or materials or both (29 CFR 1910.21(f)(27)).
Where the elevated platform in general industry is not temporary the following definition in 29 CFR 1910.21(a)(4) could apply:
Platform. A working space for persons, elevated above the surrounding floor or ground; such as a balcony or platform for the operation of machinery and equipment.
Where a working platform is part of a permanent structure and is permantly attached and located in relation to the permanent structure, the use of the term "temporary working platform" would be inappropriate.
Thank you for your concern and continuing interest in occupational safety and health.
John K. Barto,
Division of Occupational Safety Programming