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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

April 15, 1982

Mr. Paul Hancock
Steeplejack Waco Inc.
P.O. Box 708
Pinson, Alabama 35126

Dear Mr. Hancock:

Assistant Secretary Thorne G. Auchter has asked me to respond to your letter dated April 1, 1982 requesting a variance from Section 1926.451(c)(2) prohibiting the use of dis-similar metals on tube and coupler scaffolds, of the Safety and Health Regulations for Construction.

A request for a variance is limited to an employer for his affected employees. A manufacturer is not eligible to seek a variance for his product. Therefore, no further action will be taken on your request for a variance.

However, we will forward your letter to the Office of safety Compliance Programming for their evaluation. After their evaluation is complete, they will be in contact with your office.

If I can be of any assistance, please contact my office at (202) 523-7183.


James J. Concannon
Office of Variance Determination