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.

August 29, 1983

Mr. Allan H. Masinter
Lewis, Ciccarello, Masinter & Friedberg
Post Office Box 1746
Charleston, West Virginia 25326

Dear Mr. Masinter:

This is in response to your letter of August 19, 1983, to Mr. Edward Estkowski, requesting a clarification of the words "open sides" included in 29 CFR 1910.28(g)(5) for two-point suspension scaffolds.

29 CFR 1910.28(g)(5) requires as follows:


"Guardrails not less than 2x4 inches or the equivalent and not less than 36 inches or more than 42 inches high, with a mid-rail, when required, of l- x 4-inch lumber or equivalent, and toeboards, shall be installed at all open sides on all scaffolds more than 10 feet above the ground or floor. Toe-boards shall be a minimum of 4 inches in height. Wire mesh shall be installed in accordance with paragraph (a)(17) of this section."

29 CFR 1910.26(g)(11) requires as follows:


"Two-point suspension scaffolds shall be securely lashed to the building or structure to prevent them from swaying. Window cleaners' anchors shall not be used for this purpose."

Two-point suspension scaffolds complying with 29 CFR 1910.28(g)(11) do not require a guardrail at the building or structure side. However, floor openings (indentations) greater than 12 inches in the side of a building or structure, as indicated in your letter, do require guardrails at the building or structure side.

If we may be of further assistance, please contact me.


John K. Barto
Chief, Division of Occupational
Safety Programing