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.

December 22, 1987

Mr. D. Victor
Saleeby Scaffold Industry Association
14039 Sherman Way
Van Nuys, California 91405

Dear Mr. Saleeby:

This is in response to your letter of November 27, requesting a clarification of the 29 CFR [1926.452(j)(7)] requirement for pump jack scaffolds.

29 CFR [1926.452(j)(7)] requires that "if two by fours are spliced to make up the pole, the splicer shall be so constructed as to develop the full strength of the members."      (Correction 10/02/98) ["when two by fours are spliced to make a pole, mending plates shall be installed at all splices to develop the full strength of the member."]      It is the intent of the above mentioned requirement to allow the use of spliced poles for pump jacks in lieu of two continuous length poles provided the splices are constructed in a manner that develops the full strength of the spliced member. The spliced pole is required to provide the equivalent strength of two continuous length two by fours poles for pump jack scaffolds.

If we can be of further assistance, please let us know.

Sincerely,



Thomas J. Shepich, Director
Directorate of Field Programs