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.

June 29, 1977

Mr. Joseph S. Puccinelli
Vice President-Engineering
Safeway Steel Products
6228 West State Street
Milwaukee, Wisconsin 52301

Dear Mr. Puccinelli:

This is in response to your correspondence of June 3, 1977, regarding wheel locks on a special rolling scaffold to be used to erect large tanks.

The Occupational Safety and Health Administration (OSHA) has reviewed your letter and the accompanied drawing No. E-76025-4.

OSHA does not consider 29 CFR 1926.451(e) Manually Propelled Mobile Scaffolds, applicable to scaffolds, such as yours, that are: 1) limited in movement to only two directions by the use of fixed castors; and, 2) in direct contact with the structure under construction, which also limits the movement of the scaffolds to the same two directions, and 3) movable only with considerable horizontal force.

Where there are no specific scaffold standards on a particular scaffold 29 CFR 1926.451(a) Scaffolding, General Requirements, are to be met. In addition, adequate safeguards should be provided to prevent the accidental displacement of the scaffold.

If I may be of further assistance, please feel free to contact me.


John K. Barto,
Division of Occupational Safety Programming