Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

August 29, 1986

Mr. Marvin May
Power Climber
4640 Sperry Street
Post Office Box 39165
Los Angeles, California 90039-1018

Dear Mr. May:

This is in response to your letter of August 5, 1986, requesting a clarification of our scaffold standards.

It is true as indicated in your letter that 29 CFR 1926.451(i)(2) does require hangers to be designed with a support for guardrail, intermediate rail, and toeboard. However, in situations where guardrails and toeboards are designed to attach to the aluminum platforms rather than to the stirrups, we would note the violation as a de minimis violation of the existing standards. De minimis violations are violations of standards which have no direct immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation but are not included on the citation. Abatement is not required of de minimis violations.

In regards to suspending a two-point suspension scaffold by suspending two (or more) platforms, connected together by a hinge, with three hoists, such as arrangement is not prohibited by existing scaffold standards. The center hoist will be supporting a greater load than the end hoist and must be rated accordingly with the applicable standards. In addition the above scaffold system shall be designed by a qualified engineer competent in this field.

If we can be of further assistance, please let us know.


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