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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 13, 1992

Mr. Ralph E. Bennett III, PE
424 Cherry Hill Road
Dyer, Indiana 46311-3108

Dear Mr. Bennett:

This is in response to your letter of November 19, 1991, and your Fax message of January 20, 1992, in which you set forth research conclusions and other information related to Table L-3 of 29 CFR 1926.451(a)(10), a table setting forth planking requirements for scaffolds used in construction. I apologize for the delay in responding to you letter.

Your comments that minimum fiber stress and modulus of elasticity values be specified in future directives are appreciated and such action will be taken as priorities allow. In addition your comments have been forwarded to the Office of Construction and Civil Engineering Safety Standards for evaluation and possible incorporation into the final rule for scaffolds that is now being developed.

Your suggestion that compliance officers check actual plank dimensions to determine if properly sized lumber is being used has been forwarded to the Office of Field Programs for appropriate consideration.

With respect to developing future load tables, please be advised that the current Occupational Safety and Health Administration (OSHA) requirements will very likely be modified to parallel the provisions set forth in OSHA's 1986 Notice of Proposed Rulemaking for scaffolds. As you know, that document uses performance language in lieu of specification criteria and would place all the existing tables into a non-mandatory appendix. That approach allows updated information, such as you have provided, to be recognized more easily by OSHA without additional formal rulemaking. The approach clarifies that OSHA is not a design agency, however, it allows OSHA to recognize designs and criteria (such as updated ANSI A10.8 tables) that are demonstrated to be appropriate for use and which comply with OSHA's performance criteria.

If you need further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.


Patricia K. Clark, Director
Directorate of Compliance Programs