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 http://www.osha.gov.

May 2, 1983

Mr. Thomas H. Miller
Executive Secretary - Treasurer
Pennsylvania Building and
Construction Trades Council
405 City Tower
301 Chestnut Street
Harrisburg, Pennsylvania 17101

Dear Mr. Miller:

Thank you for your recent letter concerning the use of stilts in the construction industry. Your letter addressed to Assistant Secretary Auchter was forwarded to this office for reply. This also confirms your telephone conversation with Mr. Simms, a member of my staff.

The Occupational Safety and Health Regulations for Construction do not specifically require the use of stilts. We would recommend that stilts adjustable from approximately 12 inches to 36 inches be used in accordance with the manufacturer's recommendations. The stilts, under discussion, are a design similar to those depicted in the enclosed illustration. We would also caution that there may be situations, such as employees on stilts being exposed to guardrails, window openings, wall openings, rough walking/working surfaces, etc., which could present a hazard to employees and require additional safeguarding.

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

Sincerely,



Bruce Hillenbrand
Acting Director
Federal Compliance and
State Programs