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.



January 22, 2001

Douglas L. Easter
H B Training and Consulting
84-A Jopenea Blvd.
Hoschton, GA 30548

Re: 1926.451(b)(3)(ii), Drivit, synthetic stucco

Dear Mr. Easter:

This is in response to your September 11, 2000, letter to the Occupational Safety and Health Administration (OSHA) requesting an interpretation of an OSHA construction scaffold provision, 29 CFR 1926.451(b)(3)(ii), regarding synthetic stucco applications. We have paraphrased your question below.

Question: In OSHA's construction scaffold standard (29 CFR 1926 Subpart L), §1926.451(b)(3)(ii) provides: "the maximum distance from the face for plastering and lathing operations shall be 18 inches (46 cm)." Does this provision apply to "Drivit" (a synthetic stucco system) applications?

Answer: Yes. Traditional plastering and lathing involves the following steps: wood lath is attached to the wall, a metal mesh is placed over the lath, and then coats of plaster are applied. In synthetic stucco systems, such as Drivit, styrofoam sheets and fiberglass mesh take the place of the wooden lath and metal mesh. Also, the composition of the plaster-type material is different. While the materials are different, the application process is similar, and the space needed between the scaffold and the wall is the same. Therefore, we consider the Drivit system to fall within the category of "plaster and lathing operations" for purposes of this provision.

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]