Scaffolding Frequently Asked Questions
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Question 1:
Do I need to
have fall protection for employees working on the first level of a scaffolding
system?
Answer 1:
The standard
requires fall protection at more than 10 feet above the lower level for
employees. Ref: 1926.451(g)(1)
Question 2:
Can the
crossbracing for scaffold be used as the guardrail system?
Answer 2:
The crossbracing
may be used in lieu of the top rail when the crossing point is between 38
inches (0.97 m) and 48 inches (1.3 m) above the work platform, or, as a
midrail when the crossing point is between 20 inches (0.5 m) and 30 inches
(0.8 m) above the work platform. Ref: 1926.451(g)(4)(xv)
Question 3:
Can I use a
Baker scaffold which has guardrails at a height of 36 inches?
Answer 3:
The height of
the toprail for scaffolds manufactured and placed in service before January 1,
2000 can be between 36 inches (0.9 m) and 45 inches (1.2 m). The height of the
toprail for scaffolds manufactured and placed in service after January 1, 2000
must be between 38 inches (0.97 m) and 45 inches (1.2 m). Ref:
1926.451(g)(4)(ii)
Question 4:
Do the
attachable ladders for scaffolds need to extend above the landing platform on
the scaffold?
Answer 4:
While portable
ladders must meet the subpart X requirements, the scaffold standard does not
require that attachable ladders for scaffolds meet the subpart X rules.
Therefore, there is no OSHA requirement that attachable scaffold ladders
extend above the platform.
See Letter of Interpretation
Question 5:
Do the
requirements of aerial lifts, 1926.453, apply to scissor lifts?
Answer 5:
The aerial lift
requirements (§§1926.453) incorporate by reference the definition of aerial
lifts used in the American National Standards Institute (ANSI) A92.2-1969
standard. Therefore, the requirements in 1926.453 apply to equipment
identified in that 1969 ANSI consensus standard as aerial lifts. The ANSI
standard definition includes the following vehicle-mounted elevating and
rotating work platforms: "extensible boom platforms", "aerial ladders",
"articulating boom platforms", "vertical towers", and "a combination of any of
the above." Scissor lifts, including those with platforms that extend beyond
the equipment's wheelbase, do not fall within any of these categories.
Therefore, scissor lifts are not addressed by the aerial lift provisions of
Subpart L. While there are no OSHA provisions that specifically address
scissor lifts, they do meet the definition of a scaffold (§§1926.451 - general
requirements for scaffolds). Employers must therefore comply with the other
applicable provisions of Subpart L when using scissor lifts. For example,
since scissor lifts are mobile, the specific requirements for mobile scaffolds
in the scaffold standard (1926.452 (w) - mobile scaffolds) must be met.
See Letter of Interpretation
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