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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 25, 2004
Mr. Andrew C. Smith
Re: Pump jack scaffold railing, fall protection; §§1926.451(g), 1926.452(j)
Dear Mr. Smith:
This is in response to your February 18, 2004, fax to the Occupational Safety and Health Administration. You ask about the fall protection requirements for pump jack scaffold railings. We apologize for any delay in responding.
We have paraphrased your question as follows:
Question: I have submitted patent drawings1 of a pump jack pole and jack with a railing that holds 2x4s for fall protection purposes. What are the OSHA requirements that apply to these railings?2
Section 1926.451(g) Fall protection states:
(1) Each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level. Paragraphs (g)(1)(i) through (vii) establish the types of fall protection to be provided to the employees on each type of scaffold. Paragraphs (g)(2) of this section addresses fall protection for scaffold erectors and dismantlers.
Note to Paragraph (g)(1): The fall protection requirements for employee installing suspension scaffold support systems on floors, roofs, and other elevated surfaces are set forth in subpart M of this part.
Section 1926.451(g)(1)(vii) states:
For all scaffolds not otherwise specified in paragraphs (g)(1)(i) through (g)(1)(vi) of this section, each employee shall be protected by the use of personal fall arrest systems or guardrail systems meeting the requirements of paragraphs (g)(4) of this section.
Section 1926.451(g)(4) provides the requirements for guardrail systems:
Guardrail systems installed to meet the requirements of this section shall comply with the following provisions (guardrail systems built in accordance with Appendix A to this subpart will be deemed to meet the requirements of paragraphs (g)(4) (vii), (viii), and (ix) of this section): [Paragraphs (g)(4) (i)-(xv) of §1926.451 set out the required guardrail criteria.] * * *
It is important to note that the general requirements for scaffolds and their construction are set out in §1926.451. Also, §1926.452(j) Pump jack scaffolds provides additional requirements specific to pump jack scaffolds.
If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, 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
1 No engineering studies assessing the extent to which the product meets OSHA requirements were submitted to us. [ back to text ]
2 Your original question was much broader - i.e, "will this meet [the OSHA] criteria?" We do not have the resources to perform engineering analyses on product designs. However, for questions like this, we do try to give guidance on which OSHA requirements apply. [ back to text ]