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.

October 19, 2015

Mr. Shaun Garza
2800 W. Baker Street
Baytown, TX 77521

Dear Mr. Garza:

Thank you for your July 17, 2015, inquiry to the Occupational Safety and Health Administration (OSHA), Directorate of Construction. You have a specific question regarding OSHA's enforcement policy of 29 CFR 1926.452(c)(6) - Fabricated frame scaffolds (tubular welded frame scaffolds). This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.

Question: 29 CFR 1926.452(c)(6) states, "Scaffolds over 125 feet (38.0 m) in height above their base plates shall be designed by a registered professional engineer." Is this the measurement to the highest point of a scaffold or to the top platform height?

Answer: Each paragraph, 29 CFR 1926.452(c)(6) and 29 CFR 1910.28(d)(11), of the provided sections references the distance measured from the scaffold's lower baseplates to the highest point of an assembled scaffold system.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our 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 requirement discussed. Note that our guidance might be affected by changes to OSHA rules. To keep apprised of such developments and to view all OSHA standards, you can consult OSHA's website at www.osha.gov. If you have any further questions, feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,

 

James G. Maddux, Director
Directorate of Construction