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Taut rope and chain guardrails on shipyard scaffolds

Summary A shipbuilding association challenged OSHA's meaning of taut for rope or chain scaffold guardrails. OSHA disagreed and said guardrails meeting the criteria in its cited directive were taut under the shipyard standard. OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1988-08-31
Date issued
August 31, 1988
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.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OSHA archives this letter and says it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 31, 1988

Mr. W. Patrick Morris
Vice President and General Counsel
Shipbuilders Council of America
[Recipient address omitted]
Dear Mr. Morris:

This is in response to your letter of August 15, addressed to Assistant Secretary John A. Pendergrass, concerning the Occupational Safety and Health Administration's (OSHA) interpretation of 29 CFR 1915.71(j)(2) as defined in OSHA Instruction STD 3-10.3.

OSHA does not concur with the maritime industry's definition of "taut" as stated in your letter. OSHA considers that chains, and wire rope or synthetic ropes used as guardrails on scaffolding are "taut" when meeting the criteria set forth in STD 3-10.3. This interpretation does not change the intent of the standard. Therefore, STD 3-10.3 remains in effect, as a guideline, for 29 CFR 1915.71(j)(2).

Thank you for your interest in occupational safety and health.

Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs

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