- Standard Number:
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.
October 13, 1983
Dear Mr. Budd:
This is in response to your letter of September 28, 1983, concerning a possible misinterpretation of our scaffold standards.
29 CFR 1926.451(d)(7) requires the scaffold to be secured to the building or structure at intervals not to exceed 30 feet horizontally and 26 feet vertically to prevent movement of the scaffold. The Directorate of Field Operation has notified the OSHA field staff that a free standing scaffold shall be considered safe when the total height is equal to or less than four times the minimum or least base dimension.
If I may be of further assistance, please let me know.
John B. Miles, Jr., Director
Directorate of Field Operations
September 28, 1983
Mr. John Barto
Division Occupational Safety & Health Program
Suite N 3106
200 Constitution Avenue
Washington, DC 20210
Subject: Request for Program Directive
Dear Mr. Barto:
The SSEI is an organization comprised of manufacturers of scaffolding, shoring and forming equipment. The main purpose of the SSFI is to promote the safe use of that equipment. The institute accomplishes that function through the development of various safety publications, as well as serving on various ANSI Committee such as A10.8 of which we are Secretariate.
We have recently been approsed of a possible misinterpretation of OSHA Part 1926.451(d)(7). Fiske-Carter Construction Company, a South Carolina contractor, was cited by OSHA for not tieing in scaffold that was in excess of 30 feet in length.
Mr. Jay Bender, a South Carolina Hearing Officer, referred to the Texas Masonry Decision regarding the same Section and gave an interpretation as follows:
" A reading of the Standard indicated clearly that scaffold 2 feet high and 30 feet long would have to be secured to the building as the scaffold 26 feet wide and 26 feet tall."
While not contesting the citation further, Fiske-Carter did request an interpretation from the Atlanta Region office. Mr. Bunn of the office responded as follows:
"Consensus recommend that an unsecured, free standing scaffold be considered safe only when the total height is equal to or less than four times its minimum or least base dimension (width)."
Mr. Bunn's interpretation, we feel is correct. Additionally, in the latest draft revisions to the Tube and Coupler Scaffold Section of ANSI A10.8, this situation is dealt with by the following language.
"Anchor running scaffold to the wall or structure when the height exceeds four times the minimum scaffold base dimension. The first vertical and longitudinal tie shall be placed at this point. Vertical ties shall repeated at intervals not greater than 26 feet. The top shall be placed no lower four times the base dimension from the top of the completed scaffold. Longitudinal ties shall be placed at each end and at intervals not greater than 30 feet. Anchors must prevent the scaffold from tipping into or away from the wall or structure."
To clarity and further misinterpretations, the SSFI is requesting that a OSHA program directive be issued along the lines of the Atlanta Regional offices interpretation.
We would be pleased to assist in any fashion or answer any additional questions you may have regarding this request. Copies of pertinent information are enclosed.
Your response will be appreciated.
Very truly yours,
JOSEPH P. BUDD