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.

September 26, 1995

Mr. Jules DiRocco
Safety Consultant
Sun Company, Inc.
Ten Penn Center Market Street
Philadelphia, Pennsylvania 19103-1699

Dear Mr. DiRocco:

This is in response to your letter of June 20 to the Occupational Safety and Health Administration (OSHA) in which you asked if one person could act as a competent person for multiple scaffolding activities which are not necessarily in close proximity to each other.

29 CFR 1926.451[(f)(7)] states, "No scaffold shall be erected, moved, dismantled, or altered except under the supervision of competent persons."      (Correction 10/07/98) ["scaffolds shall be erected, moved, dismantled, or altered only under the supervision and direction of a competent person qualified in scaffold erection, moving, dismantling or alteration. Such activities shall be performed only by experienced and trained employees selected for such work by the competent person."]      [1926.451(b)] defines a competent person as, "...one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them."

OSHA's position is that one person can act as a competent person for multiple sites, so long as the competent person can make the frequent and regular inspections as required by §1926.20(b)(2) and supervises the erection, movement, dismantlement, and alteration of any of the scaffolds under the person's control.

If you have any questions, please call me or [Mr. Noah Connell] of my staff at [(202) 219-7207].


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