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.


October 2, 2008

Mr. Sahag Ohanesian
239 High St.
Medford, MA 02155

Dear Mr. Ohanesian:

Thank you for your August 7, 2008, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). You had a specific question regarding the OSHA standards on scaffolding. Your paraphrased question and our response are below. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence.

Scenario: In designing a frame for a generator, a scaffold has been added to the sides of the frame to improve safety. The frame is to be designed to carry the 100,000-pound load of the generator (which includes the safety factor), plus the 64,000-pound load of the scaffolds (which includes the safety factor of four). The scaffold itself will meet 29 CFR 1910.28(a)(4), which states:

Scaffolds and their components shall be capable of supporting without failure at least four times the maximum intended load.

Question: Must the generator frame also support four times the intended load, meaning the generator frame must support a 400,000-pound load?

Response: No. The intent of the standard is for the scaffold and its components to be able to support four times the intended load on the scaffold. The generator frame, in this scenario, would be considered to be the anchorage or footing for the scaffold, and as such, would have to meet §1910.28(a)(2), which states:

The footing or anchorage for scaffolds shall be sound, rigid, and capable of carrying the maximum intended load without settling or displacement. Unstable objects such as barrels, boxes, loose brick, or concrete blocks shall not be used to support scaffolds or planks.

 

 

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 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. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs