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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 13, 1982

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

Dear Mr. Hancock:

This is in response to your letter of April 27, 1982, concerning the use of tube and coupler scaffolds.

29 CFR 1926.451(c)(5) does prohibit the use of dissimilar metals for tube and coupler scaffolds, because permanent use of dissimilar metals such as aluminum tubes and steel clamps would reduce the design strength of the scaffold. However, tube and coupler scaffolds with dissimilar tubes and clamps used for short periods of time without deterioration or distortion, would comply with 29 CFR 1926.451(c)(5). Any clamps or tubing deteriorated or distorted shall be removed from service immediately.

OSHA Program Directive CPL 2-11A (copy enclosed) provides guidelines on de minimis violations which have no direct or immediate relationship to safety and health. If an employer complies with the clear intent of the standard, but deviates from its particular requirements in a manner which has no direct or immediate relationship to safety and health the alleged violation is noted by the compliance officer as a de minimis violation. Penalties are not proposed and abatement is not required for de minimis violations.

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


John K. Barto
Division of Occupational Safety Programming