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.

July 23, 2001

Jim Brown
Director of Safety and Health
Associated General Contractors
1050 Market Tower
10 West Market Street
Indianapolis, IN 46204

Re: 29 CFR 1926.451 (e)(1) and (c)(2)(iii); scaffolds; cantilevered work platforms

Dear Mr. Brown:

This is in response to your May 14, 2001 letter to the Occupational Safety and Health Administration (OSHA). In your letter you request clarification on how 29 CFR 1926.451(e)(1) applies to access to cantilevered work platforms. As you describe your scaffold, the platforms at issue are mounted on side brackets and are more than 24 inches below the adjacent scaffold work platforms or decks. More specifically, you would like to know if you may stack blocks for the required access. Additionally, you noted a concern that such objects would create an obstruction hazard on the side bracket platform.

In regards to the first part of your question, when a work platform is more than 24 inches below its point of access, you must provide a means of access to it such as a portable ladder, hook on ladder, or attachable ladder. Specifically, §1926.451(e)(1) states:

When scaffold platforms are more than 2 feet (0.6 m) above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used. Cross-braces shall not be used as a means of access.

For the situation you described, the deck inside the scaffold uprights provides the access point to the side-bracket platform. Since the vertical distance between these two levels exceeds 2 feet (24 inches), then you must provide one of the means of access described in §1926.451(e)(1).

In answer to your specific question, providing stacked blocks does not meet OSHA's requirements for safe access. As required by §1926.451(e)(1), you will need to provide a means of access to and from the side bracket work platform deck meeting the requirements listed above. Additionally, stacking blocks, bricks, tile, and other similar materials to raise the level of the work platform deck or a portion of it effectively creates a new work platform.

Section 1926.451(c)(2)(iii) prohibits the use of "unstable objects" as a working platform (i.e., the top of the blocks would become the new work platform deck). Unstable objects are defined in §1926.450(b) as:

Items whose strength, configuration, or lack of stability may allow them to become dislocated and shift and therefore may not properly support the loads imposed on them. Unstable objects do not constitute safe base support for scaffolds, platforms, or employees. Examples include, but are not limited to, barrels, boxes, loose brick, and concrete blocks.

Loose bricks and concrete blocks are unstable objects.

Lastly, in your letter you expressed concern that placing an object on the cantilevered work platform would create an obstruction on the work platform that in turn would create an additional hazard for employees working on the platform. Poorly placed access could create an obstruction, but this hazard could be minimized by placing the access point at one end of the work platform. This, in turn, would maximize the working area, and employees would have an access point that would meet the requirements of §1926.451(e)(1).

If you require any further assistance, please do not hesitate to contact us again by writing to: [Directorate of Construction - OSHA, Office of Construction Standard and Guidance], Room N3468, 200 Constitution Avenue NW, Washington, D.C. 20210.


Russell B. Swanson, Director
Directorate of Construction