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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 6, 1997

Mr. R. B. Jacobsen
Assistant Manager Safety
Raytheon Constructors Inc.
P.O. Box 8223
Philadelphia, PA 19101-8223

Dear Mr. Jacobsen:

This is in response to your telefax of October 22, regarding the applicability of an Occupational Safety and Health Administration (OSHA) letter of interpretation (dated April 7, 1987) concerning "equivalent safe access" (see section 1926.451(a)(13) of the old standard) as it relates to scaffolds, in light of the recently revised standard for scaffolds used in the construction industry (61 FR 46026).

As you know, section 1926.451(e) of the revised standard addresses the requirements for access to scaffolds. The revised standard no longer uses the term "equivalent safe access," nor does it explicitly address the matter of climbing over or through guardrails as constituting unsafe access. Unobstructed access to the platform is an important component of safe access and therefore, OSHA recommends that provisions for safe access be made in all guardrail systems. Moreover, the practice of climbing over or through guardrails is widely regarded by the industry to be hazardous, when particular circumstances on a jobsite make clear the existence of a serious hazard, OSHA would consider issuing a citation under the General Duty Clause of the OSH Act.

If you require any further assistance, please do not hesitate to contact us again by writing to:


Directorate of Construction - OSHA
Office of Construction Standards and Compliance Assistance Room N3621
200 Constitution Avenue, N.W.
Washington, D.C. 20210


Russell B. Swanson, Director
Directorate of Construction