- Standard Number:
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 http://www.osha.gov.
March 17, 1998
Mr. Dale Shoemaker
United Brotherhood of Carpenters Apprenticeship Training Department
101 Constitution Avenue NW
Washington D.C. 20001
Dear Mr. Shoemaker:
This is in response to your letter of April 1 addressed to Bill Burke of the Occupational Safety and Health Administration (OSHA) in which you asked for interpretations regarding OSHA's revised scaffold standard, which was promulgated in August 1996.
You have asked about the applicability of the Subpart L scaffold standards to the use of shoring frames in two situations: 1.) When the shoring frames are erected for purposes of shoring but will also support temporary decks and work platforms; and 2.) When shoring frames are used in place of regular scaffolding components to support temporary work platforms for purposes other than shoring. In either case the assembly would indeed qualify as a "scaffold," which the standard defines as "any temporary elevated platform (supported or suspended) and its supporting structure (including points of anchorage) used for supporting employees or materials or both." The provisions of Subpart L would thus apply to both the completed assembly and to its erection and dismantling. The Subpart L provisions would not apply only if the shoring frames are used solely for shoring and not to support a working surface.
Although, as noted, Subpart L includes provisions applicable to the erection and dismantling of scaffolds (these provisions became effective on September 2, 1997,) the standard recognizes that full compliance may be infeasible under some circumstances or may create greater hazards to employees. We are attaching for your information a copy of the recently completed memorandum to our field offices that explains our current enforcement policy on this issue.
We hope this explanation adequately addresses the concerns raised in your letter. Thank you for taking the time to provide us with these comments. Please do not hesitate to contact the Directorate of Construction, 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