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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.
February 27, 1992
Mr. Larry Liang Zhou
2706 Highway 421 North
Wilmington, North Carolina 28401
Dear Mr Zhou:
This is in response to your January 24 letter in which you request the Occupational Safety and Health Administration (OSHA) to formally state its policy on the use of laminated veneer lumber in lieu of scaffold grade planks on scaffold systems. I apologize for the delay of this response.
As set forth in OSHA Instruction STD 3-10.1B, it has been determined that laminated planking can be used in lieu of solid sawn lumber for scaffold planks when engineering data shows equivalency. This policy was incorporated into the November 25, 1986 publication of a Notice of Proposed Rulemaking for scaffolds used in construction (51 FR 42680); the November 29, 1988 Notice of Proposed Rulemaking for scaffolds used in shipyards (53 FR 48182); and in the April 10, 1990 Notice of Proposed Rulemaking for scaffolds used in general industry (55 FR 13360). Although none of these proposals have become final rules yet, it is not anticipated that the policy on laminated planks will change when the final rules are published.
If we may be of further assistance, please do not hesitate to contact Mr. Dale Cavanaugh or Mr. Roy Gurnham of my staff in the Office of Construction and Maritime Compliance Assistance.
Patricia K. Clark, Director
Directorate of Compliance Programs