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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.
March 12, 2002
Wood Advisory Services, Inc.
P.O. Box 1322
Millbrook, NY 12545
Dear Mr. DeBonis and Mr. Anderson:
This is in response to your letter that we received February 12, 2002, requesting that the Occupational Safety & Health Administration (OSHA) consider instituting a requirement that all scaffold planks meet a "scaffold grade" requirement under recognized grading rules.
First, you are correct in that §1926.451 does not require that planking be scaffold grade or equivalent, as recognized by approved grading rules for the species of wood used. Instead, §1926.451(a)(1) requires that each scaffold and scaffold component be capable of supporting, without failure, its own weight and at least four times the maximum intended load applied or transmitted to it. Section 1926.451(a)(6) requires that scaffolds be designed by a qualified person and constructed and loaded in accordance with that design. Non-mandatory Appendix A contains examples of design and construction measures that employers may use to comply with the "capacity" and "scaffold platform construction" provisions in §1926.451(a) and (b).
The issue of grading and stamping scaffold planks was specifically considered during the rulemaking process for 29 CFR 1926 Subpart L. The Agency found that the comments did not support the conclusion that scaffold planks must be graded and stamped by a qualified grading agency. The comments and analysis are located in the Federal Register at 61 FR 46035-46038, August 30, 1996; for your convenience the web site is http://www.osha.gov/FedReg_osha_data/FED19960830A.html.
We appreciate your strong interest in this matter and your comments will be retained for further consideration if OSHA decides to revisit those aspects of the rule.
Russell B. Swanson, Director
Directorate of Construction