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February 18, 1997


Carol Mick
Klamath Basin Home Builders Assn.
4509 S Sixth Street # 110
Klamath Falls OR 97603-4867


Dear Ms. Mick:


This is in response to your letter regarding the new federal rules on scaffolding in construction and the proposed Oregon OSHA adoption of them.


You refer first to 1926.451(g)(2) about erectors and dismantlers using personal fall protection. The key word in that paragraph is "feasible." This paragraph does not require all erectors and dismantlers to always use personal fall protection. It only requires that if such use is feasible and does not create a hazard to worker's, they MUST use it. Notice also that the requirement is further refined in that it applies only to "supported" scaffolds.


You also refer to 1926.451(g)(3) about attaching lifelines to the scaffolding itself. Note that the paragraph also says that the tie-off requirements are "in addition to meeting the requirements of 1926.502(d)." That paragraph requires, among other things, that the tie-off point be able to stand a 5,000 pound load. Thus if the tie-off point on your scaffolding can stand a 5,000 pound load, we would allow workers to be tied off to it.


Otherwise, they cannot tie off to the scaffolding. This paragraph then is permissive, not restrictive. I suspect you are right when you say that manufacturer's do not recommend tie-off to their scaffolds, probably because they know they will not hold 5,000 pounds.


We hope this will clarify some of your concerns about these new rules. For further information contact Ron Preece at 378-3272. You are also invited to see the OR-OSHA pages on the Internet at www.cbs.state.or.us/external/osha/index.html.


Sincerely,


Marilyn K. Schuster, Manager
Standards & Technical Resources Section
Oregon Occupational Safety & Health Division


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