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.

December 11, 2001

Mr. W. E. Stader
Safety Consulting Services, Inc.
25 Franklin Road
Roanoke, Virginia 24011

Re: Scaffold guardrails on wall (interior) side

Dear Mr. Stader:

This is in response to your July 20, 2001 correspondence to the Occupational Safety and Health Administration (OSHA) requesting clarification of OSHA's scaffolding standard. Specifically, you ask if a guardrail is required on the interior or wall side of the scaffold, as you believe the wall or outriggers would prevent a fall. You enclosed a copy of the tube and coupler scaffold sketch from the standard, which does not include an interior top, or mid rail.

29 CFR Part 1926, Subpart L, Appendix E
The tube and coupler scaffold illustration you submitted from Appendix E and its companion titled "Bracing-Tube and Coupler Scaffolds" depicts scaffold bracing and tie spacing patterns as well as component nomenclature, not necessarily proper guardrail systems. For your future reference, the illustration titled "Bracing – Tube and Coupler Scaffold" shows the relationship between the building face and the scaffold railing. We apologize for any confusion this may have caused.

Fall Protection on Scaffolds
OSHA scaffolding standards are at 29 Code of Federal Regulations 1926.451–1926.454. The scaffolding fall protection requirements are located in §1926.451(g). Depending on the type of scaffold, each employee more than 10 feet above a lower level must be protected from falling either by a personal fall arrest system, a guardrail system, or both. When using a guardrail system, all open sides and ends must be guarded as specified in paragraph (g)(4)(i) of §1926.451, which reads in part: "Guardrail systems shall be installed along all open sides and ends of platforms . . . ." [emphasis added.]

Exceptions
However, there are exceptions to the requirement to install guardrails at the front edge of scaffold platforms. Section 1926.451(b)(3) does not require fall protection or guardrails when: (1) the front edge of the platform is 14 inches (36 cm) or less from the face of the work; (2) when outrigger scaffolds are 3 inches (8 cm) or less from the front edge;1 and (3) when employees are plastering and lathing 18 inches (46 cm) or less from the front edge. Also, under §1926.451(g)(1)(vi), when performing overhand bricklaying operations, there need not be a guardrail on the side next to the wall being laid.

In addition, during the erection and dismantling of a scaffold, fall protection is not required when a competent person determines it would be infeasible or create a greater hazard to provide such protection, as stated in §1926.451(g)(2).

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

Sincerely,



Russell B. Swanson, Director
Directorate of Construction

[Corrected 7/18/05]

 

 


1 The standard defines outrigger scaffold in §1926.450 as "a supported scaffold consisting of a platform resting on outrigger beams (thrustouts ) projecting beyond the wall or face of the building or structure, the inboard ends of which are secured inside the building or structure."] [ back to text ]