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.

April 11, 2005

Mr. Douglas A. Holman
1816 River Bend Road
Sevierville, TN 37876

Re: Whether a safety factor must be incorporated into the design of footings for supported scaffolds under the requirements of 29 CFR 1926.451(c)(2)(i)

Dear Mr. Holman:

You have submitted nine letters to the Occupational Safety and Health Administration (OSHA) containing a number of questions on the construction scaffold standard (29 CFR Part 1926 Subpart L).
1 We will be responding in a series of separate letters in response; this is the fourth in that series.

We have paraphrased your question regarding footings and the application of safety factors as follows:

Question: Section 1926.451(c)(2)(i) requires that the footing for a scaffold be "capable of supporting the loaded scaffold without settling or displacement." Does this provision require that a safety factor be applied?

Answer: 1926.451(c)(2)(i) states:

Footings shall be level, sound, rigid, and capable of supporting the loaded scaffold without settling or displacement.

There is no statement in this provision indicating that a safety factor must be incorporated into the design of footings for supported scaffolds. The language of §1926.451(c)(2)(i) simply establishes a required result — the footing must be capable of supporting the loaded scaffold without settling or displacement. As long as that result is achieved, the requirement is met. Since the provision does not state that a safety factor must be applied, none is required, so long as the design achieves this result.

Note, though, that as a practical matter, since it is often difficult to predict the exact amount of the total load, the qualified person
2 will usually need to be conservative in estimating the total load to ensure that the footing will in fact be able to support the loaded scaffold and meet the requirements in §1926.451(c)(2)(i).3

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.


Russell B. Swanson, Director
Directorate of Construction



1 When we originally received these questions from you in April 2003, it was unclear to us if you were requesting a response to each or if they were submitted only to call our attention to these issues in the event that OSHA were to do further rulemaking on the standard. We attempted to resolve that with you, but we were unable to obtain a response; consequently, our office closed the file. After your communications with my staff on January 13, 2005, we understand now that you are requesting a response to each question. We apologize for the misunderstanding and resulting delay in providing this response. [ back to text ]





2 Under §1926.451(a)(6), a qualified person is required to design the scaffold. [ back to text ]





3 See also our letter of August 1, 2000, to Mr. Kemp for further information on what §1926.451(c)(2)(i) requires. [ back to text ]