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 6, 1992
Mr. John P. Cupp, Jr.
P.O. Box 566
Feasterville, PA 19053-0566
Dear Mr. Cupp:
This is in response to your recent letter in which you request the Occupational Safety and Health Administration (OSHA) to review your Pole-Cupps scaffold support system.
As you know, it is the policy of the Occupational Safety and Health Administration not to approve or endorse products. The variable working conditions at jobsites and possible alteration or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the product manufacturer. However, we have reviewed the information provided in your letter and it appears the Pole-Cupps system, if properly installed on a sufficiently strong roof, would provide adequate scaffold support and be in compliance with OSHA's scaffold rules.
If we can be of further assistance, please don't hesitate to contact either myself or Mr. Dale Cavanaugh of my staff at (202) 219-8136.
Roy F. Gurnham, Esq., P.E.
Office of Construction and Maritime