Warning tags on scaffolds during erection

June 24, 1992

John Palmer, Director
Scaffold Training Institute
[Recipient address omitted]
Dear Mr. Palmer:

This is in response to your April 6 letter requesting a clarification of the Occupational Safety and Health Administration policy for warning tags on scaffolds. I apologize for the delay of this response.

Presently, there is no requirement that warning tags be placed on all scaffolds while they are being erected. Although there are instances where such tags are appropriate and a citation under 29 CFR 1926.200(h)(1) could be issued, there are also many instances where such would not be appropriate. An example of the latter is where a large scaffold is being built in phases or sections, employee access to the completed sections of the scaffold would not be prohibited. A tag which limits access to erection and disassembly crews on that portion of a scaffold being changed could be appropriate but a case by case determination is necessary.

I believe this is what the compliance officers meant when they indicated to you that they are in agreement and "might even use 200(h)(1) for a citation if the situation warranted".

If you have further questions, please contact [Mr. Noah Connell] of my staff in the office of Construction and Maritime Compliance Assistance at [(202) 219-7207].

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]