OSHA Instruction STD 3-10.2 OCT 30, 1978

OSHA PROGRAM DIRECTIVE #100-32

TO: ASSISTANT REGIONAL DIRECTORS/OSH

Subject: 29 CFR 1926.451(i)(8) Multistage Suspension Scaffolds

1. Purpose

To provide specific interpretation of 29 CFR 1926.451(i)(8).

2. Directives Affected

None.

3. Interpretation

Questions have arisen relating to the application of 29 CFR 1926.451(i)(8) to multistage suspension scaffolds. Multistage suspension scaffolds have two or more stages (platforms) and the usual method of fabrication results in rigid end suspension members structure. If 29 CFR 1926.451 (i)(8) were applicable to multistage suspension scaffolds. personnel on the various stages of the scaffold would have to be secured to the building structure. In the event of failure of one of the suspension lines, employees on the lower levels of the multistage scaffolding would be subject to a greater hazard by attaching their safety belts to the building structure than by attaching their safety belts to a suitable member of the scaffold structure.

Subpart D of 29 CFR 1910 is currently being revised and one proposed part will address this subject. It will require personnel on multistage instead of to the building structure. It is also proposed that a like standard will be promulgated in 29 CFR 1926.

The Construction Standards were promulgated by the Construction Safety Task Force as provided by PL 91-54 prior to passage of the Occupational Safety and Health Act of 1970. Several members of the original task force have been contacted and their statement is that at the time 1926.451 (i)(8) was promulgated that there was no intent for the standard to apply to a suspension scaffold having more than one platform. There, 1926.451 (i)(8) shall not apply to multistage suspension scaffolds.

OSHA Instruction STD 3-10.2 OCT 30, 1978

4. Action

Pending final promulgation of the standard, an alleged violation for failure of the employee to tie-off on the scaffold structure shall be cited under 5(a)(1) of the Act, providing it merits the requirement of a serious violation.

Barry J. White Associate Assistant Secretary for Regional Programs

DISTRIBUTION:

NATIONAL OFFICE FIELD

A/Sec. (3) Assistant Regional Directors/OSH (3) Dep. Asst./Sec. (2) AARD Technical (2) Spec. Asst. (1) AARD Training (2) Associate Asst./Sec (3) AARD Federal/State (2) Office Directors (3) Area/District Offices (3) Division Chiefs (1) Training Institute (10) SOL (35) Professional Staff (1 ea.) BLS (1) Designated State Agencies (1) Review Commission (6) NIOSH Regional Program Directors (1) HEW (1) SOL Regional Attorneys (1) OGO Professional Staff (50) Review Commission Regional OS Professional Staff (50) Offices (1) NACOSH Committee (1) Regional Directors (1)