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.

MEMORANDUM FOR:     GERALD P. REIDY
                    Regional Administrator

FROM:               John B. Miles, Jr., Director
                    Directorate of Field Operations

SUBJECT:            Evaluation of the "Rustgo Work Platform"

Re: Region II Memorandum of February 13, 1985 concerning the above mentioned subject.

The Rustgo work platform used at a construction project is a mobile scaffold which must comply with the scaffold standards regulated in 29 CFR 1926.451 [and 1926.452(w)]. Based on the information provided by the manufacturer's brochure and a telephone conversation between a company official and a member of my staff, it appears the Rustgo work platform was designed to comply with the requirements for mobile scaffolds. The company official stated that the Model 195 and the Model 139 platforms have been tested when they have been raised to their highest level with at least four times the specified maximum workload. Compliance officers performing OSHA inspections where the Rustgo work platforms are being used by the employer shall enforce 29 CFR 1926.451 [and 1926.452(w)], requirements for manually propelled mobile scaffolds.