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.



August 1, 2001

Mr. Phil Work
Indian Mill & Lumber, Inc.
11107 Jones Road West
Houston TX 77065

Re: Acceptability of the Pin-Lok scaffold plank product.

Dear Mr. Work:

This responds to your April 3, 2000 letter to the Occupational Safety and Health Administration (OSHA), requesting a letter stating that the Pin-Lok scaffold plank product manufactured by Indian Mill & Lumber, Inc., meets the specified engineering criteria for wood scaffold planks.

Our Office of Engineering Services conducted an independent structural analysis of the planks using the submitted information. They determined that the plank meets the OSHA requirements for factor of safety and deflection for the loads and spans specified in the brochure attached to your request titled "Indian Mill & Lumber, Inc. IM&L, Revolutionizing the Scaffold Industry, Pinned Scaffold Planks." While the plank meets the OSHA requirements for these loads and spans, its safe use depends on the consumer following the manufacturer's recommendations.

If we can be of further assistance, please contact us again by writing to: Directorate of Construction - OSHA, Office of Construction Standards and Compliance Assistance, Room N3468, 200 Constitution Avenue, NW, Washington, DC 20210.


Russell B. Swanson, Director
Directorate of Construction