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.

April 20, 1998

Mr. James Naylor
Safety Consultant
Safety Check, Inc.
9823 South Carls Drive
Plainfield, IL 60544

RE: 1926.451(b)(2); 1926.451(e); 1926.451(g)

Dear Mr. Naylor:

This is in response to your July 16, 1997 letter to the Occupational Safety and Health Administration (OSHA) in which you asked for an interpretation of OSHA's requirements when working from concrete formwork. We apologize for the lateness of this response.

Your request specifically referred to a photograph of an employee standing on a 2 X 4 waler attached to formwork. The employee is approximately four feet off the ground. The 2 X 4 platform in your photo is considered a scaffold under 29 CFR 1926 subpart L. That regulation defines a scaffold as "any temporary elevated platform (supported or suspended) and its supporting structure (including points of anchorage), used for supporting employees or materials or both." Therefore, the waler must meet the requirements in subpart L.

One of those requirements is that scaffold platforms be at least 18" wide (1926.451(b)(2)). Your photo depicts what appears to be a waler bracket, not a scaffold bracket. Scaffold brackets that can accommodate an 18" platform are available. In addition, section 1926.451(e) requires that employees have a safe means of access to the scaffold.

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