Construction first aid, scaffolds, lifts and roof access

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 20, 1992

MEMORANDUM FOR: HARVEY E. HARRIS, Director
Office of Training and Education

THROUGH: BRUCE HILLENBRAND,
Director Federal-State Operations

FROM: PATRICIA K. CLARK, Director
Directorate of Compliance Programs

SUBJECT: Construction Interpretation Issues

This is in response to your November 20, 1991, memorandum requesting information and interpretations on eight construction issues. I apologize for the delay of this response.

1. First aid kits must be available for each shift of operation in all situations where a first aider is required to be present by the provisions of 1926.50(c). A trained first aid provider must have the proper supplies in order to render effective first aid.
2. The requirement for guarding scaffolds that are less than 45 inches (1.14m) wide applies to the working/walking platform, not the frame upon which the platform rests. However, please be advised that the requirement applies only to makeshift scaffolds. The requirement does not apply to the types of scaffolds addressed by 1926.451(b) through (y). This is clarified in the 1986 notice of proposed rulemaking (NPRM) for Subpart L--Scaffolds used in Construction (51 FR 42680).
3. Although the existing regulations, the 1988 ANSI rules, and the 1986 proposed OSHA rules do not require the use of ladders during erection and dismantling operations, it is strongly recommended that ladders be used whenever feasible. To this end, scaffold frame ladders meeting the criteria set out in the 1986 NPRM, would be acceptable for use as ladders.
4. Body belt/harness systems are not required on scissor lifts. (Please be advised that these types of scaffolds are now addressed by ANSI A 92.3-1990).
5. The body belt/harness systems requirement is limited to only extensible and articulating boom supported platforms as covered by ANSI A 92.2-1990.

The illustration submitted in your letter that shows a "self-propelled aerial platform with articulating boom" is taken from the SIA Handbook. Mr. Vic Saleeby of the SIA has stated that the illustration is misnamed and the platform shown as item E should not be identified as an articulating boom. This office agrees. However, whatever the proper name, the key to the application of .556(b)(2)(v) is whether or not the entire boom mounted platform can be positioned outside the wheel base. If so, then body belt/harness systems are required. The system shown in your example cannot be so positioned.

6. The 1986 NPRM proposed a maximum distance of 14 inches (35.6 cm) of open space be allowed before guardrails are required. There were no comments to the record that indicated this limit should be changed. Although the 1988 ANSI standard recognizes a distance of 16 inches for supported scaffolds and 12 inches for suspension scaffolds, we are not aware of the justification and do not recognize those limits.
7. Paragraph 1926.105 can be cited if it is possible for an employee to fall from a steep sloped roof that has eaves less than 16 feet (4.9 m) above the ground, and ladders, scaffolds, catch platforms, temporary floors, or body belt/harness systems are not in use. However, given your example, if the fall is more likely to occur over the gable (sloped) edge rather than the eave, then 1926.105 would be more appropriate as 1926.451(u)(3) is intended for protection from falls over eaves which are more than 16 feet from the ground.

Steep roof fall hazards are more clearly addressed in the 1986 NPRM for Subpart M--Fall Protection (51 FR 42718).

8. Rest platforms for scaffold ladders are not required by the existing rules (except for mobile scaffolds), nor are they required by the 1988 ANSI standard for construction scaffolds. Whether or not there should be a rest platform requirement is an issue discussed in the 1986 NPRM.