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.

June 14, 1999

Mr. Don A. Halperin
10835 NW 18 Court
Gainesville, FL 32606

Re: 29 CFR 1926. 450, 451; Safety Requirements for Metal Deck Platforms on Manually Propelled Scaffolds.

Dear Mr. Halperin:

This is in response to your letter dated April 27, 1999, addressed to Mr. Charles N. Jeffress, Assistant Secretary of Labor, requesting OSHA's interpretation as to whether metal decking must be secured when used as a platform on a manually propelled scaffold.

Generally, a platform must either be secured or extend out at least six inches
One of the general requirements for scaffolds is §1926.451(b)(4), which states that "each end of a platform, unless cleated or otherwise restrained by hooks or equivalent means, shall extend over the centerline of its support at least six inches." Therefore, if platforms are not attached, they must extend out at least six inches. This mandate does not distinguish between metal and non-metal decking.

A qualified person must determine if the platforms need to be attached
Under §.451(a)(6), scaffolds must be constructed in accordance with design plans provided by a qualified person ("one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project"). The qualified person must indicate in the design plans either that the platform is to be attached or must extend over the centerline of its support by at least six inches.

The competent person must determine if unattached platforms will stay in place
Section .451(f)(7) requires scaffolds to be erected, moved, dismantled, or altered only under the supervision and direction of a competent person qualified in scaffold erection, moving, dismantling or alteration (a competent person is "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are...hazardous, or dangerous...and who has authorization to take prompt corrective measures..."). Workers may remain on a movable scaffold while it is moved only under the supervision of a competent person (and only if the additional requirements in §.452(w)(6) are met). If a qualified person has designed the movable scaffold with unattached platforms, workers may remain on the platform while the scaffold is moved only if the competent person determines that the unsecured platform will maintain the six inch minimum overhang.

If you require further assistance, please do not hesitate to contact us again by writing to: U. S. Department of Labor (OSHA), Office of Construction Standards and Compliance Assistance, Room N3467, 200 Constitution Avenue, N.W., Washington, D.C. 20210.

Sincerely,

Russell B. Swanson
Director
Directorate of Construction