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.

Apr 16, 2018

Mr. Jeffrey A. Spatz
The Graham Company
One Penn Square West
Philadelphia, PA 19102

Dear Mr. Spatz:

Thank you for your March 24, 2018, letter we received via email to the Occupational Safety and Health Administration (OSHA) Directorate of Construction regarding applicability of scaffold fall protection requirements to guardrails near ladder access areas on scaffolds.

We have paraphrased your question as follows:
Question: Common industry practice is to install ladder access to form scaffolds at an end of a form scaffold where there is a guardrail system installed along the open sides and ends of the platform except at the end where the ladder access is located. Does this practice meet the requirements of 29 CFR 1926 451(g)(4)(i)?

Answer: No, 29 CFR 1926 451(g)(4)(i) requires that guardrail systems be “...installed along all open sides and ends of platforms.” These fall protection requirements for Subpart L are set forth in §1926.451(g) (General requirements) and apply to all scaffold systems, including form scaffolds. A similar question was answered in a letter to Mr. Holman on June 20, 2005. The Holman letter’s interpretations also apply to the scenario you have described above.

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 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 requirement discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in responses to new information to keep apprised of such developments, you can consult OSHA’s website at http://www.osha.gov. If you have any further questions, feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,

 

Dean McKenzie, Director
Directorate of Construction