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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.
January 5, 2009
Letter # 20080910-8622
Re: Whether catch platforms (used to catch an employee in the event of a fall from a working surface above) must comply with OSHA's scaffold standard, Subpart L.
Question: Are temporary catch platforms – used to catch employees who might fall from a working surface above, or falling objects – subject to the requirements of the construction scaffold standard, 29 CFR 1926 Subpart L?
Answer: Yes. The temporary catch platforms you describe are covered by 1926 CFR Subpart L. Section 1926.450(b) defines a scaffold as:
[A]ny temporary elevated platform (supported or suspended) and its supporting structure (including points of anchorage), used for supporting employees or materials or both.
In this instance, if an employee or material were to fall onto the temporary catch platform, it would at that point support "employees or materials or both." Consequently, it meets the definition of a scaffold. Therefore, the catch platforms must comply with the applicable 1926 Subpart L requirements. These include, among others, the 4:1 strength requirements in 1926.451(a)(1).1
Noah Connell, Acting Director
Directorate of Construction
1 Note that, in calculating the loads for this purpose, you must include the impact forces due to the fall of an employee or materials.[ back to text ]