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Fall protection during scaffold erection and dismantling

Summary OSHA told its regional administrators that workers erecting or dismantling scaffolds did not have to wear a safety belt and lanyard at every moment. It said protection was needed during stationary work where it could practically be used, while constant use during scaffold assembly could itself be hazardous. OSHA now archives this memorandum as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1985-08-02
Date issued
August 2, 1985
Status
Archived by the agency
OSHA archives this memorandum and says it may no longer represent OSHA policy.
Status last verified October 10, 2026

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The current status of this document is unclear
OSHA archives this memorandum and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 2, 1985


MEMORANDUM FOR: All Regional Administrators

FROM: John B. Miles, Jr., Director
Directorate of Field Operations

SUBJECT: Fall Protection for employees engaged in erecting or dismantling scaffolds in the Construction Industry


It is not the intent of the construction scaffold standards to specifically require employees who erect or dismantle scaffolds to use a safety belt and lanyard at all times. However, employees erecting or dismantling scaffolds must wear safety belts and lanyards in performing work at a stationary location for a period of time which allows the practical use of safety belts and lanyards. It is OSHA's position that requiring the constant wearing of belts and lanyards while erecting or dismantling scaffolds could be hazardous to employees.
The Directorate of Safety Standards Programs anticipates publishing a new proposal for Subpart L - Ladders and Scaffolding later this year. The fall protection proposed for employees erecting/dismantling scaffolds will be specifically included in that proposal and the text contains a provision which will exempt employees engaged in erecting or dismantling scaffolds from using any fall protection.

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