Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

February 11, 1982

Mr. Harold Gidish
Power Climber Inc.
P. O. Box 39759
4560 Sperry Street
Los Angeles, California 90039

Dear Mr. Gidish:

This is in response to your letter of January 28, 1982, concerning the use of non-flowable material for counter weights in rigging outrigger beams.

The OSHA construction standards do not specifically state that non-flowable material must be used to counter weight outrigger beams for two point suspension scaffolds. However, 29 CFR 1926.451(a)(2) requires the footing or anchorage for scaffolds to be sound, rigid, and capable of carrying the maximum intended load without settling or displacement. Thus, non-flowable materials installed to counter weight outrigger beams must comply with this intent. The counter weighting of outrigger beams is prohibited for other types of suspension scaffolds in the applicable paragraphs of 29 CFR 1926.451.

The use of flowable materials (such as sand in burlap bags) as counter weights for outrigger beams is hazardous with deterioration or displacement of the burlap bags. Employees have been injured or killed because the sand bags used as counter weights deteriorated and/or were displaced, which allowed the swing stage to fall to the ground. The above conditions may be cited as an alleged violation of 29 CFR 1926.451(a)(2) and (a)(7).

This regulation is currently under review and this problem will be specifically addressed in our Subpart L proposal.

If I may be of further assistance, please call or write.


John K. Barto
Division of Occupational Safety Programming