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.

March 11, 1983

MEMORANDUM FOR: Stanley Elliot
Area Director, Pittsburgh
SUBJECT: Clarification of 29 CFR 1926.451(a)(4) Relative to Scaffold Heights Under Ten (10) Feet

This memorandum was prepared in response to your written request of March 3, 1983 for clarification of Construction Standard 1926.451(a)(4) which requires standard guardrails on scaffolds 4 to 10 feet in height and having minimum horizontal dimension in either direction of less than 45 inches.

The National Office of Compliance Programming interpretation is that the particular vertical standard for scaffolds applies in this case. Examination of 1926.451(a) for Tubular Welded Frame Scaffolds (The Bailey scaffold appears to be this type) indicates that no minimum dimension of scaffold is specified and there is no guardrail requirement for scaffolds under 10 feet in height.

Thus, the Regional Office interpretation is that guardrails are not required for the subject scaffold for heights under 10 feet, except for adjacent dangerous equipment and similar hazards. If you have additional questions please contact Bill Thomas in the Technical Support Group of this office.

Acting Regional Administrator