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.



May 18, 2000

Mr. A. Roger Paulson
Vice Pres. of Sales and Marketing
Master Coating Technologies
2740 31st Ave. South
Minneapolis, MN 55406

Re: 1926.450; 1926.451; 1926.452; 1926.454; Mobile Scaffold

Dear Mr. Paulson:

This is in response to your January 18 letter to the Occupational Safety and Health Administration (OSHA) in which you ask us to comment on the OSHA construction regulations that would apply to the use of your product. We apologize for the delay in responding to your request.

You describe this product as a portable, single-person, mobile work platform. It is designed so that the worker, while standing on the platform (and supported by a railing), can move it. This is done by manually manipulating a "T-bar," located at the top of the platform. The T-bar is connected by a vertical shaft to the front wheels' axle.

You state that, in your view, it should be considered a scaffold rather than a ladder because it is assembled at the job site, and employees can face any direction while working on it. You specifically ask whether OSHA standards would permit a worker to move the scaffold while on it.

Subpart L — Definition of Scaffold
Section 1926.450 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." The standard further defines a mobile scaffold to mean "a powered or unpowered, portable, caster or wheel-mounted supported scaffold." It appears from the information and the drawings provided that your device meets both of these definitions . Employers would be required to comply with the general requirements of subpart L (§§1926.450, 1926.451, 1926.452, 1926.454), as well as the specific provisions for mobile scaffolds (§1926.452(w)).

Riding Mobile Scaffolds
Since your scaffold is designed for a worker to ride on it while propelling it, in addition to the general provisions, employers would have to comply with §§1926.452(w)(1) - 1926.452(w)(3) and 1926.452(w)(5) - 1926.452(w)(10). Because your device is manually propelled, rather than propelled with a motor, §1926.452(w)(3), rather than (w)(4), applies. It requires that when manual forces are used to move a scaffold, the forces shall be applied as close to the base as practicable, but not more than five feet (1.5 m) above the supporting surface. Although the T-handle is located at the top of the scaffold, the force on the handle is transmitted through the shaft down to the front base (through a bushing on the base frame). If as it appears, that the propelling forces are, in effect, applied at the base of the scaffold, then the requirement that the propelling force be applied as close to the base as possible (and not more than 5 feet above the supporting surface) would be met.

Note that among the other applicable provisions is §1926.452(w)(6), which specifies the requirements when the employees are riding a mobile scaffold.

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction

[Corrected 6/2/2005]