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.

May 27, 2004

Mr. B. Orr
Address Withheld

Re: Use of an extension cord while moving a scissor lift; requirement to secure or barricade a ladder; Part 1926 Subpart L (Scaffolds)

Dear Mr. Orr:

This is in response to your letter dated received April 22, 2004, to the Occupational Safety and Health Administration (OSHA). You ask about the requirements in 29 CFR Part 1926 regarding the use of an airless spray pump while working from a scissor lift.

We have paraphrased your question as follows:

Question: Scenario: an employee was using an airless spray pump while working from a scissor lift. An extension cord connected the pump to a power source on the opposite side of the room. I was on a ladder in an area between the scissor lift and the power source. When the scissor lift was moved, the cord moved up the side of my ladder until there was no more slack in the cord. At that point it pulled on the ladder and made it tip, causing me to fall. Do OSHA standards prohibit the use of an extension cord while the scissor lift is in the air or moving?

Answer:
There is no specific OSHA construction standard addressing the use of extension cords while working from a scissor lift. Neither §1926.451, "General Requirements" for scaffolds, nor §1926.452(w), "Mobile Scaffolds," addresses this issue.

Note that §1926.1053(b)(8) states:

Ladders placed in any location where they can be displaced by workplace activities or traffic, such as in passageways, doorways, or driveways, shall be secured to prevent accidental displacement, or a barricade shall be used to keep the activities or traffic away from the ladder.

Under this section, where it is reasonably foreseeable that a workplace activity could displace a ladder, the ladder must be secured or a barricade used to keep "the activities" away. However, without a detailed description of the area in question, we cannot comment on whether this provision would have required securing the ladder or placing barricades in the scenario you describe.

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,


Russell B. Swanson, Director
Directorate of Construction