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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

April 19, 1994

Mr. Clark W. Thompson, P.E.
Vice President
United Form Services, Inc.
417 Main - P.O. Box 28
Neodesha, Kansas 66757

Dear Mr. Thompson:

This is in response to your July 2 letter requesting a compliance determination from the Occupational Safety and Health Administration (OSHA) regarding your "Girder Lock Overhang Form System." I apologize for the delay in responding to your inquiry.

We have reviewed the product information that you provided and have determined that if the C-Caddy is used as described in your letter, OSHA would consider it a suspended scaffold and the requirements in 1926 Subpart L (1926.451) would apply. This determination is contingent upon the crane hoist drum being dogged off and the C-Caddy being stationary at all times while employees are on the platform. A safe means of access and egress is required to and from the C-Caddy and as stated in your letter, all persons must be tied-off while on the platform.

Please note that if the C-Caddy is moved while employees are on it, OSHA would consider it a crane suspended personnel platform and the requirements contained in 1926.550(g) would apply.

If you wish to apply for a formal variance from one or more of these standards, please refer to 29 CFR 1905 and contact OSHA's Office of Variance Determination in the Directorate of Technical Support at (202) 219-7193.

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.


Roy F. Gurnham, P.E., J.D.
Office of Construction and Maritime
Compliance Assistance

July 2, 1993

Office of Construction & Maritime
Compliance Assistance
Occupation Safety and Health Administration
Room N3610
200 Constitution Avenue
Washington, DC 20210

Dear Mr. Roy Gurnham;

Enclosed are Erection Drawings, Packing Lists, Erection Manual and Technical Data Sheet for our "Girder Lock Overhang Form System".

Please review this System in general and specifically the access platform attached to the lower portion of the C-Caddy shown on drawing E-3 for compliance with OSHA requirements. In addition to the safety notes shown, we have also required that the crane line be dogged off before personnel are allowed on the platform and that a trial lift be performed each time the crane is set up in a new location. This platform was designed following OSHA guidelines 1926.451 since it is attached to the gang forms and is never manned when in motion. An OSHA audit specialist has contended that 1926.550(g) applies.

I look forward to your response concerning this system. If you have any questions please call me.


Clark W. Thompson, P.E.
Vice President