Rules for rolling rooftop suspension scaffolds

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 2, 1994
Mr. Richard Hill
Hill Equipment
[Recipient address omitted]
Dear Mr. Hill:
This is in response to your letter of December 28, 1993, in which you request a clarification of the Occupational Safety and Health Administration's (OSHA) safety regulations for roof top rolling scaffolds.
As you point out in your letter, roof cars are neither defined nor specifically addressed in OSHA's existing regulations. However, this does not mean that the general rules and some two-point suspension rules do not apply to such systems. In discussing those rules, I will discuss your concerns in the same order that you present them in your letter.
Paragraph 1926.451(h)(4) does require outrigger beams to be securely fastened or anchored, however, this rule only applies to mason's adjustable multiple-point suspension scaffolds. The rule does not apply to rolling roof rigs.
Paragraph 1926.451(k)(10) does reference the requirements of ANSI A120, however, the rule applies only to single-point adjustable suspension scaffolds. Most rolling roof rigs are two-point systems and the referenced ANSI rule could not be applied to them without using the general duty clause (Section 5(a)(1) of the Occupational Safety and Health Act of 1970.) As you know, that clause requires each employer to furnish employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious harm.
With regard to possible conflict between 1926.451 and 1910.66, please be advised that the June 30, 1993, Federal Register notice (58 FR 35076) does not list 1910.66 as a standard to be applied to construction activities. Therefore, no conflict can exist. Similarly, the construction standards do not apply to general industry activities.
Your concerns about the structural adequacy of the outrigger beams, improper counterweights, and carriages are presently addressed by 1926.451(a)(3) and (a)(7) for construction scaffolds, and by 1910.28(a)(4) for general industry scaffolds.
If you have further questions, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.
Sincerely,
Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance
Enclosure

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