

April 20, 1998

Mr. James Naylor
Safety Consultant
Safety Check, Inc.
9823 South Carls Drive
Plainfield, IL 60544

RE: 1926.451(b)(2); 1926.451(e); 1926.451(g)

Dear Mr. Naylor:

This is in response to your July 16, 1997 letter to the Occupational Safety and Health Administration (OSHA) in which you asked for an interpretation of OSHA's requirements when working from concrete formwork. We apologize for the lateness of this response.

Your request specifically referred to a photograph of an employee standing on a 2 X 4 waler attached to formwork. The employee is approximately four feet off the ground. The 2 X 4 platform in your photo is considered a scaffold under 29 CFR 1926 subpart L. That regulation defines a scaffold as "any temporary elevated platform (supported or suspended) and its supporting structure (including points of anchorage), used for supporting employees or materials or both." Therefore, the waler must meet the requirements in subpart L.

One of those requirements is that scaffold platforms be at least 18" wide (1926.451(b)(2)). Your photo depicts what appears to be a waler bracket, not a scaffold bracket. Scaffold brackets that can accommodate an 18" platform are available. In addition, section 1926.451(e) requires that employees have a safe means of access to the scaffold.



Russell B. Swanson, Director
Directorate of Construction