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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.
April 2, 1998
Mr. John Palmer
Scaffold Training Institute
Houston Training Center
311 East Walker
League City, TX 77573
Subject: 1926.502(d)(15) and 1926.451(a)
Dear Mr. Palmer:
This is in response to your letter of October 31,1997, addressed to Roy Gurnham, Occupational Safety and Health Administration (OSHA), in which you highlighted the concerns using the scaffold as an anchorage point for a personal fall arrest system under 29 CFR 1926.502(d)(15) as well as meeting the requirements of 1926.451(a).
It is OSHA's position that scaffolding can function as a suitable anchorage for fall arrest systems when the scaffolding section so used is erected and braced such that the criteria of 1926.502(d)(15) are met. This applies whether the scaffold is partially built (i.e., being erected or disassembled) or completely built. The provisions of paragraph 1926.502(d)(15) require the anchorage (i.e., the scaffold) either to be capable of supporting at least 5000 pounds, or to be designed, installed, and used as part of a complete personal fall arrest system which maintains a safety factor of at least two.
You are correct that both safety factors -- the two to one for the personal fall arrest system and the four to one for the scaffold components -- must be maintained. However, the 4 to 1 factor for a component required by section 1926.451(a) applies only to the load which is actually applied or transmitted to the component, not to the total load placed on the scaffold.
While the typical erected scaffold may not withstand the forces imposed by an arrested fall, with proper engineering, a scaffold can be designed so that its components are adequately braced or supported to support such loads. A scaffold should never be used as an anchorage point for a fall arrest system unless it has been properly evaluated by a competent person.
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.
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