• Standard Number:
    1910.29(a)(3)

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 https://www.osha.gov.

January 12, 1976

Mr. Joseph M. Karch
Manager of Safety and Training
Essex Chemical Corporation
1401 Broad Street
Clifton, New Jersey 07015

Dear Mr. Karch:

This is in response to your letter requesting clarification of the use of guardrails and swivel locks on mobile scaffolds.

Your letter mentions 1926.451 as a source for interpretation and then also mentions 1910.29. When referring to the OSHA Part 1926, the standards apply to construction work only. When referring to Part 1910, the standards apply to General Industry. Under 1910.29(a)(3)(vii) [page 23529 of FR39-#125 dated June 27, 1974], it specifies guardrails are required at 10 foot or more above ground. Also, in 1910.29(a)(4)(ii), it specifies that at least two of any four casters shall be provided with positive wheel locks. These facts are duplicated in 1926.451(e)(2) for locking casters and in 1926.451(e)(10) for guardrails [FR dated June 24, 1974 Volume 39 #122]. No specific platform size is mentioned in relation to Manually Propelled Mobile Scaffolds whereas 1926.451(a)(4) would modify all scaffold platforms where one horizontal dimension is 45 inches or less in construction only. This does not apply to the General Industry Standards 1910.29(a)(3).

Please feel free to contact us if there are further questions about OSHA.

Sincerely,



Alfred Barden
Regional Administrator
Occupational Safety and Health