May 2, 1983

Mr. Thomas H. Miller
Executive Secretary - Treasurer
Pennsylvania Building and
Construction Trades Council
405 City Tower
301 Chestnut Street
Harrisburg, Pennsylvania 17101

Dear Mr. Miller:

Thank you for your recent letter concerning the use of stilts in the construction industry. Your letter addressed to Assistant Secretary Auchter was forwarded to this office for reply. This also confirms your telephone conversation with Mr. Simms, a member of my staff.

The Occupational Safety and Health Regulations for Construction do not specifically require the use of stilts. We would recommend that stilts adjustable from approximately 12 inches to 36 inches be used in accordance with the manufacturer's recommendations. The stilts, under discussion, are a design similar to those depicted in the enclosed illustration. We would also caution that there may be situations, such as employees on stilts being exposed to guardrails, window openings, wall openings, rough walking/working surfaces, etc., which could present a hazard to employees and require additional safeguarding.

If I may be of further assistance, please feel free to contact me.

Sincerely,



Bruce Hillenbrand
Acting Director
Federal Compliance and
State Programs