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Permanent billboard platforms versus scaffolds

Summary A billboard association asked how OSHA classified walking decks attached to billboards. OSHA said a permanent platform fixed to a structure should not be called a temporary scaffold, while the applicable definition depended on the platform's actual construction and use. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1977-04-19
Date issued
April 19, 1977
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 19, 1977

Mr. Wilson Tanner,
Associate Vice President
Outdoor Advertising Association
of America, Inc.
[Recipient address omitted]
Dear Mr. Tanner:

This is in response to your letter of March 9, 1977, regarding a question on walking surface platforms attached to a billboard. In addition, it confirms your telephone conversation with a member of my staff.

The question posed is "Does OSHA consider walking surface platforms (or decks or catwalks) to be permanent or temporary, or do they consider it nothing at all?" It would be inappropriate for the Occupational Safety and Health Administration (OSHA) to answer this question as presented, due to the connotations that may be involved.

OSHA's general industry scaffolding terms defines a scaffold as any temporary elevated platform and its supporting structure used for supporting workmen or materials or both (29 CFR 1910.21(f)(27)).

Where the elevated platform in general industry is not temporary the following definition in 29 CFR 1910.21(a)(4) could apply:

Platform. A working space for persons, elevated above the surrounding floor or ground; such as a balcony or platform for the operation of machinery and equipment.

Where a working platform is part of a permanent structure and is permantly attached and located in relation to the permanent structure, the use of the term "temporary working platform" would be inappropriate.

Thank you for your concern and continuing interest in occupational safety and health.

Sincerely,

John K. Barto,
Chief
Division of Occupational Safety Programming

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