Scaffold hazard training requirements

Each employee who performs work while on a scaffold must be trained by a person qualified in the subject matter to recognize scaffold hazards and control them. See 1926.454(a) and the general training duty in 1926.21(b)(2).

• The standard uses the phrase “qualified in the subject matter,” meaning the trainer must have sufficient knowledge of the specific scaffold hazards and controls for the scaffold type in use.
• Employers are responsible for ensuring this training occurs before employees perform work on scaffolds.

Scaffold users must be trained to recognize electrical hazards, fall hazards, and falling object hazards in the work area. See 1926.454(a)(1).

• Training should make workers aware of where those hazards exist and how they may arise during scaffold work.

Scaffold users must be trained in the correct procedures for dealing with electrical hazards and for erecting, maintaining, and disassembling the fall protection systems and falling object protection systems being used. See 1926.454(a)(2).

• Training should cover how to safely install and remove guardrails, toeboards, nets, personal fall arrest systems if applicable, and how to avoid electrical contact when working near energized parts.

Training must teach employees the proper use of the scaffold and the proper handling of materials on the scaffold. See 1926.454(a)(3).

• This includes safe methods for climbing on and off the scaffold, correct placement of tools and materials to avoid overloading or tripping hazards, and safe material hoisting practices.

Training must include the maximum intended load and the load-carrying capacities of the scaffolds used. See 1926.454(a)(4).

• Workers should know the rated capacity and how to recognize when a scaffold is being overloaded so they can avoid unsafe loading.

It means scaffold-user training must also cover other rules in Subpart L that apply to the work being done, beyond the items listed in 1926.454(a). See 1926.454(a)(5).

• Examples could include requirements from related Subpart L sections on access, platform construction, plank inspection, or specific scaffold types; employers should review Subpart L and include any applicable topics in training.

Employees who erect, disassemble, move, operate, repair, maintain, or inspect a scaffold must be trained by a competent person to recognize hazards associated with that work. See 1926.454(b).

• The standard requires a higher level of training (delivered by a "competent person") for those performing hands-on scaffold construction, dismantling, movement, maintenance, operation, repair, or inspection tasks.

Training must include the nature of scaffold hazards so employees can recognize the types of risks they will encounter while erecting, disassembling, moving, operating, repairing, maintaining, or inspecting scaffolds. See 1926.454(b)(1).

• Topics should include fall risks, collapse or structural failure, falling objects, improper ties or supports, electrical contact, and hazards from tools/materials.

A competent person must train workers in the correct procedures for erecting, disassembling, moving, operating, repairing, inspecting, and maintaining the specific type of scaffold in question. See 1926.454(b)(2).

• Training should be scaffold-type specific (e.g., supported frame, suspension, aerial lift) and include step-by-step safe procedures, use of required tools, sequencing, and when to stop work and consult the competent person.

Training must cover the design criteria, maximum intended load-carrying capacity, and intended use of the scaffold being worked on. See 1926.454(b)(3).

• Employees should learn how design features affect safe use, how to verify capacity (plank ratings, platform spans), and what uses are prohibited (e.g., using scaffold as a crane).

It requires inclusion of any additional Subpart L requirements that apply to scaffold erection, use, or inspection tasks. See 1926.454(b)(4).

• Examples: tie-in spacing, stabilization, scaffold component inspection criteria, and requirements for fall protection from 1926.451(g) and falling object protection in 1926.451(h). For application to conveyances/suspended scaffolds see OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

Employers must retrain employees whenever they lack the skill or understanding needed for safe scaffold work, including when worksite or equipment changes introduce new hazards or when inadequate job performance shows lost proficiency. See 1926.454(c).

• Specific triggers are listed in 1926.454(c)(1)–(3).

Yes — if changes at the worksite create hazards about which an employee has not been previously trained, the employer must retrain that employee so they regain the required proficiency. See 1926.454(c)(1).

• Examples: new adjacent operations, altered scaffold anchorage points, or newly exposed electrical lines.

Employees must be retrained when changes in the types of scaffolds, fall protection, falling object protection, or other equipment introduce hazards about which they were not previously trained. See 1926.454(c)(2).

• For example, switching from a supported frame scaffold to a suspended scaffold or introducing a new personal fall arrest system would trigger retraining.

Retraining is required when inadequacies in an employee's scaffold work indicate they have not retained the requisite proficiency. See 1926.454(c)(3).

• If an employee repeatedly makes unsafe choices, misuses equipment, or commits deviations that could cause injury, the employer must provide retraining.

No — 1926.454 does not set a fixed calendar interval for retraining; retraining is required when the employer has reason to believe an employee lacks the necessary skill or understanding (for example, due to site changes, equipment changes, or demonstrated inadequacy). See 1926.454(c).

• Employers should monitor performance and site/equipment changes to determine when retraining is needed.

Yes — 1926.454 distinguishes the trainer qualifications: scaffold users must be trained by a person "qualified in the subject matter" under 1926.454(a), while those who erect, disassemble, move, operate, repair, maintain, or inspect scaffolds must be trained by a "competent person" under 1926.454(b).

• A "qualified" trainer has the specific knowledge to teach the hazards and controls; a "competent person" is someone who can identify hazards and has the authority to take corrective action (see definitions in Subpart L and OSHA guidance at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05).

If employees perform work while on a scaffold or are involved in erecting, disassembling, moving, operating, repairing, maintaining, or inspecting a scaffold, they must receive the applicable training: users per 1926.454(a) and those involved in erection/movement/inspection per 1926.454(b).

• Delivering materials to the scaffold without performing work on it may not always trigger user training, but anyone who climbs onto the scaffold or participates in erecting/moving it must be trained appropriately.

Yes — scaffold inspectors are listed among those who must be trained by a competent person to recognize hazards associated with the work in question, the same requirement that applies to erectors and dismantlers. See 1926.454(b).

• Inspector training should include how to identify structural defects, improper assembly, missing components, and when to remove a scaffold from service.

Yes — scaffold training must cover fall hazards and falling object hazards and the correct procedures for fall and falling object protection systems, as required by 1926.454(a)(1)–(2). OSHA's interpretation about suspended scaffolds also directs that fall protection must meet the requirements of 1926.451(g) and falling-object protection must meet 1926.451(h), as explained in OSHA's letter at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

• Include practical instruction on correct anchor points, use of guardrails, personal fall arrest systems, toeboards, screens, and debris nets when applicable.

Section 1926.454 does not itself require employers to keep written training records; it requires that training be provided. See 1926.454. Employers should also review 1926.21(b) and their company policies for any recordkeeping expectations.

• While 1926.454 is silent on documentation, maintaining written records is a good best practice to demonstrate compliance and to track who needs retraining when site or equipment changes occur.

An employer may accept outside training so long as the training meets the requirements of 1926.454 and is delivered by a person who is either "qualified in the subject matter" (for users) or a "competent person" (for erectors/inspectors). See 1926.454(a) and 1926.454(b).

• The employer retains responsibility to ensure the training content and trainer qualifications meet the standard and that employees are proficient after training.

A "qualified person" for training (used in 1926.454(a)) is someone with recognized knowledge, training, or experience in the subject matter sufficient to train scaffold users; a "competent person" (used in 1926.454(b)) is someone who can identify existing and predictable hazards and has authority to correct them. See 1926.454(a), 1926.454(b), and OSHA's scaffold/fall protection clarification at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

• In practice, a competent person typically has both the technical knowledge and the authority on site to stop work and require corrective action, while a qualified trainer must be technically competent to teach but need not have site authority unless also designated a competent person.

The employer must retrain the employee so they regain the requisite proficiency when inadequacies in scaffold work indicate the employee has not retained required skills. See 1926.454(c)(3).

• Retraining should target observed deficiencies and may include additional supervised practice, evaluation by the competent person, and follow-up monitoring.

Yes — training must be applicable to the type of scaffold being used; both 1926.454(a) and 1926.454(b) require training that relates to the hazards and correct procedures for the specific scaffold type. See 1926.454(a) and 1926.454(b)(2).

• For example, a suspended scaffold user must be trained on suspension-specific hazards and controls, not just general scaffold topics; OSHA's interpretation on suspended scaffolds is at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

Yes — training must include the proper handling of materials on the scaffold and correct procedures for the fall and falling-object protection systems used, which applies to suspended or conveyance-type scaffolds. See 1926.454(a)(2)–(3) and OSHA's suspended scaffold guidance at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

• Practical instruction should address safe loading, securing materials to prevent falling, and limits on material placement relative to platform capacity.