August 29, 1986

Mr. Marvin May
Power Climber
4640 Sperry Street
Post Office Box 39165
Los Angeles, California 90039-1018

Dear Mr. May:

This is in response to your letter of August 5, 1986, requesting a clarification of our scaffold standards.

It is true as indicated in your letter that 29 CFR 1926.451(i)(2) does require hangers to be designed with a support for guardrail, intermediate rail, and toeboard. However, in situations where guardrails and toeboards are designed to attach to the aluminum platforms rather than to the stirrups, we would note the violation as a de minimis violation of the existing standards. De minimis violations are violations of standards which have no direct immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation but are not included on the citation. Abatement is not required of de minimis violations.

In regards to suspending a two-point suspension scaffold by suspending two (or more) platforms, connected together by a hinge, with three hoists, such as arrangement is not prohibited by existing scaffold standards. The center hoist will be supporting a greater load than the end hoist and must be rated accordingly with the applicable standards. In addition the above scaffold system shall be designed by a qualified engineer competent in this field.

If we can be of further assistance, please let us know.

Sincerely,



John B. Miles, Jr., Director
Directorate of Field Operations