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.

June 8, 1998

Douglas A. Holman
1816 River Bend Road
Sevierville, TN 37876

RE: 1926.452(w)(2), [1926.452(w)(3)], [1926.452(w)(6)(iv)]

Dear Mr. Holman:

This is in response to your letters, dated June 12, 1997, addressed to Mr. Roy Gurnham and myself, asking for a clarification of OSHA's mobile scaffold standard §1926.452(w). Your questions related specifically to Baker style scaffolds and whether a person could move and work from this type of scaffold, without dismounting, with the casters in the unlocked position. We apologize for the delay in this response.

Baker scaffolds, sometimes referred to as Perry scaffolds, are covered by the mobile scaffold Section of Subpart L. Section 1926.452(w)(2) requires the casters and wheels to be locked when in use. If a device were installed to permit the casters to be locked while on the scaffold, this requirement could be met without dismounting.

Section [1926.452(w)(6)] specifies the requirements for riding a scaffold. Where these conditions are met, the scaffold may be moved while employees are on it.

You asked for clarification on Sections [1926.452.452(w)(3)] and [1926.452(6)(iv)]. These sections address the manual and powered forces used to move the scaffold. When manually moving the scaffold, the force should be applied as close to the base a practicable, but not more than 5 feet (1.5 m) above the supporting surface. Your letter describes a worker standing on a Baker scaffold that is 2 to 4 feet high. The worker holds onto something overhead and moves the scaffold with his or her feet. Since the force being applied to the scaffold is less than 5 feet from the ground level, this is acceptable as long as it is the lowest point practicable. When using a power system to move the scaffold, the forces must be applied directly to the wheels. (This section would not apply to workers manually moving a scaffold.)

If you require any further assistance, please do not hesitate to [contact us by fax (202-693-1689) at: U.S. Department of Labor — OSHA, Directorate of Construction, Office of Construction Standards and Guidance. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, DC 20210; although, there will be a delay in our receiving correspondence by mail.]



Russell B. Swanson, Director
Directorate of Construction

Corrected on 03/30/2006