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.

February 24, 1997

Mr. Douglas A. Holman
1816 Bend Road
Sevierville, Tennessee 37876

Dear Mr. Holman:

This is in response to your telefax transmission of January 9, concerning the duties of the competent person during the erecting, dismantling and moving of scaffolds.

Paragraph 1926.451(f)(7) does not preclude the competent person from assisting in the erecting, dismantling, moving or altering of a scaffold. The intent is that the competent person be on site to identify hazards and take corrective action. Work site circumstances and conditions would definitely have an effect on the role that the competent person must perform. Large scale or complicated projects might preclude the competent person from actually taking part in the work in order to function as a competent person. On the other hand, smaller, straight forward projects might not preclude the competent person from actually doing some of the work.

For example: During erection, the competent person may take on the role of the lead person, while during the movement of the scaffold the competent person may act as an observer to ensure that the scaffold does not contact energized power lines or other obstacles, and not actually engage in the work of moving the scaffold.

If you have any further questions, please contact:


The Office of Construction Standards and Compliance Assistance
U.S. Department of Labor - OSHA
200 Constitution Avenue, N.W. Room N3621
Washington, D.C. 20210


Russell S. Swanson, Director
Director of Construction