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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.
July 26, 2005
Christopher R. Tschida
M.A. Mortenson Company
700 Meadow Lane North
Minneapolis, MN 55422
Re: Walkways within scaffolds, guardrails, and planking; §1926.450(b) and §1926.451(g)(1)(v)
Dear Mr. Tschida:
This is in response to your later dated April 26, 2005. We apologize for the delay in our response.
We have paraphrased your questions as follows:
Question (1): Is a walkway located in a scaffold required to have guardrails along all open sides?
Answer: No. Section 1926.451(g)(1)(v) states:
Each employee on a walkway located within a scaffold shall be protected by a guardrail system (with minimum 200 pound toprail capacity) installed within 9½ inches (24.1 cm) of and along at least one side of the walkway. [Emphasis added.]
Walkway is defined by §1926.450(b) as:
a portion of a scaffold platform used only for access and not as a work level.
Thus, where an employer is using a walkway located in a scaffold exclusively as access and not as a work area, guardrails are only required on one side of the walkway.1
Question (2): Is a walkway located in a scaffold required to be fully planked or decked?
Answer: No. Section 1926.451(b)(1) "Exception to paragraph (b)(1)" states:
The requirements in paragraph (b)(1) to provide full planking or decking does not apply to platforms used solely as walkways or solely by employees performing scaffold erection or dismantling. In these situations, only planking that the employer establishes is necessary to provide safe working conditions is required.
Therefore, walkways are not required to be fully planked. Employers must provide enough planking as necessary to make using the walkway safe for the employees.
If you need any further information, please contact us by facsimile at: U.S. Department of Labor - OSHA, Directorate of Construction, Office of Construction Standards and Guidance 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, NW, Washington, DC 20210; although, there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction
1 As emphasized in the preamble's discussion of §1926.451(g)(1)(v) in volume 61 of the Federal Register at page 46066:
If work activities other than access are performed on or from the walkway, then the platform is not considered to be a walkway * * * and other provisions of paragraph (g)(1), as appropriate, would apply.