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.

June 17, 2005

Gary C. Hay
Occupational Safety Services, Inc.
12956 Mallard Creek Drive
Palm Beach Gardens, FL 33418

Re: §1926.452(w)(2); moving mobile scaffolds.

Dear Mr. Hay:

This is in response to your letter, dated January 7, 2005, to the Occupational Safety and Health Administration (OSHA), asking for a clarification of OSHA's mobile scaffold standard. Your question relates specifically to scaffolds that are frequently moved to accommodate overhead work. We apologize for the delay in responding.

We have paraphrased your question as follows:

Question: I understand that §1926.452(w)(2) requires the wheels on a mobile scaffold to be locked when the scaffold is used "in a stationary manner." We repeatedly reposition our scaffolds (every few minutes) in the course of doing overhead work. In this situation, is the scaffold being used "in a stationary manner" or is it permissible to work from the scaffold without constantly locking and unlocking the wheels?

Answer: Title 29 CFR 1926.452(w)(2) provides:

Scaffold casters and wheels shall be locked with positive wheel and/or wheel and swivel locks, or equivalent means, to prevent movement of the scaffold while the scaffold is used in a stationary manner.

The purpose of this provision is to ensure that, when workers are performing tasks while on a mobile scaffold, the scaffold will remain stationary. Accordingly, when performing tasks, the casters/wheels must be locked. The only reason the Agency conditioned the locking requirement on use of the scaffold "in a stationary manner" was to accommodate the fact that the casters/wheels have to be unlocked for the scaffold to be moved between tasks.

Therefore, in the situation you describe, although the scaffold is moved very frequently and remains in one place for only a few minutes at a time, the standard requires that while the work tasks are performed, the scaffold (which at that point is being used in a stationary manner) must have its wheels/casters locked.

Note that, as OSHA indicated in a letter to Douglas A. Holman dated June 8, 1998, a way of complying with this provision without having to constantly dismount and re-mount the scaffold is to use a scaffold fitted with a device that permits the worker to lock and unlock the casters/wheels while on the scaffold.1

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 Employees are permitted to remain on a mobile scaffold while it is being moved, provided that the requirements of §1926.452(w)(6) are met. [ back to text ]