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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 25, 1995

Mr. David Glabe
Western Falsework Engineering, Inc.
P.O. Box 211336
Denver, Colorado 80221

Dear Mr. Glabe:

This is in response to your May 11, memorandum requesting the Occupational Safety and Health Administration (OSHA) to comment on the Scaffold Industry Association testing procedures to determine fall arrest tie-off locations during the erection and dismantling of scaffolds.

We have reviewed the procedure and offer the following comments:

Under the section "General Rules for all Tests", rule 3 references erection, dismantling, and use. We would recommend you remove the reference to "use." Once the scaffold system is in use, guardrails would be in place and tie-off would not apply.

In several areas of the test procedures, you specify testing the least stable or weakest configuration. We would recommend that you modify this to make it clear that your intention is to test the least stable or weakest configuration you would expect to find using proper erection or dismantling procedures. That is, you would not expect to find employees dismantling or erecting scaffolding several sections high without all the required components in place in the lower sections.

If you have further questions on this matter, please contact me or [Mr. Noah Connell] of my staff at [(202) 219-7207.]

Thank you for your interest in occupational safety and health.


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