OSHA Instruction STD 3-10.6 AUG 16, 1982 Office of Compliance Programming

SUBJECT: 29 CFR 1926.451(w) and 1926.451(a)(18) As Applied to Welding Required on Float or Ship Scaffolds.

A. Purpose. This instruction clarifies the application of the subject standards to welding on float or ship scaffolds.

B. Scope. This instruction applies OSHA-wide.

C. Action. OSHA Regional Administrators/Area Directors shall take action to ensure that 29 CFR 1926.451(w) and 1926.451(a)(18) are enforced in accordance with E. of this instruction.

D. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

2. Explain the technical content of the change to the State designee as requested.

Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing, within 30 days of notification, to the Regional Administrator. This acknowledgment should include a description either of the State's plan to implement the change or of the reasons why the change should not apply to that State.

4. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in actual performance.

OSHA Instruction STD 3-10.6 AUG 16, 1982 Office of Compliance Programming

E. Guidelines.

1. 29 CFR 1926.451(w)(1) states in part that float or ship scaffolds shall not be used to support more than three men and a few light tools, such as those needed for riveting, bolting, and welding. Therefore, welding on the scaffolds is allowed, provided the supporting rope is free from defects.

2. 29 CFR 1926.451(w)(5) allows employers to use float or ship scaffolds supported with 1-inch diameter manila rope or equivalent, free from deterioration, chemical damage, flaws or other imperfections.

Each employee shall be protected by an approved safety lifebelt and lifeline, in accordance with 29 CFR 1926.451 (w)(6).

F. Background. 29 CFR 1926.451(a)(18) requires that no welding, burning, riveting, or open flame work shall be performed on any staging suspended by means of fiber or synthetic rope. However, 1926.451(a)(18) refers to 1926.451(w) for specific requirements for float or ship scaffolds, which clearly contemplates that welding will be performed from float or ship scaffolds. Thus, welding from float or ship scaffolds is not forbidden by OSHA's regulations. However, 29 CFR 1926.451(w)(5) requires that supporting ropes shall be 1-inch diameter manila rope or equivalent, free from deterioration, flaws or other imperfections.

Thorne G. Auchter Assistant Secretary

DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional program Directors