Scaffolds requirements overview

A scaffold is any temporary elevated platform (supported or suspended) and its supporting structure used to support employees or materials, and a suspension scaffold is one or more platforms suspended by ropes or other non-rigid means from an overhead structure.

• This definition appears in the scaffold definitions within 29 CFR 1926 Subpart L; see Scaffolds, 29 CFR 1926 Subpart L for the full standard.
• The definition is the baseline for deciding which provisions of Subpart L apply (e.g., fall protection, planking, and fall-object protection).

Yes — a conveyance operating in temporary guides or with incomplete guides meets OSHA's definition of a suspended scaffold and is subject to Subpart L.

• OSHA concluded that a conveyance operating in or with temporary or incomplete guides meets the definition of a suspended scaffold in the letter of interpretation "Scaffold and fall protection clarification" (Dec. 5, 2023) and therefore must comply with Subpart L; see Scaffolds, 29 CFR 1926 Subpart L.

Yes — a conveyance suspended by temporary suspension means (for example, temporary cables) is considered a suspended scaffold under OSHA's definition.

• OSHA explicitly states this in the interpretation "Scaffold and fall protection clarification" (Dec. 5, 2023).
• Once it meets the suspended scaffold definition it must comply with the requirements in 29 CFR 1926 Subpart L.

Yes — a conveyance utilizing a temporary hoist machine meets OSHA's definition of a suspended scaffold.

• OSHA addressed this configuration in "Scaffold and fall protection clarification" (Dec. 5, 2023) and treated such conveyances as suspended scaffolds under Subpart L.
• Consequently, applicable suspended scaffold rules in 29 CFR 1926 Subpart L apply.

Yes — a conveyance that uses one or more temporary devices in combination with a permanent car frame or frame plus temporary working platform meets OSHA's definition of a suspended scaffold.

• OSHA stated in "Scaffold and fall protection clarification" (Dec. 5, 2023) that combinations of temporary suspension/guide/hoist devices with permanent car components fall within the suspended scaffold definition.
• When that definition is met, the conveyance must follow the requirements in 29 CFR 1926 Subpart L.

Suspended scaffolds (including conveyances that meet the suspended scaffold definition) must provide fall protection that complies with the fall protection requirements in 29 CFR 1926.451(g).

• OSHA's December 5, 2023 letter "Scaffold and fall protection clarification" (Dec. 5, 2023) states that any configuration meeting the suspended scaffold definition must meet the fall protection rules found in 29 CFR 1926.451(g).
• Employers should consult the text of 29 CFR 1926 Subpart L for the specific options and conditions that satisfy 1926.451(g).

Employees working from suspended scaffolds must have overhead and falling object protection that meets the requirements in 29 CFR 1926.451(h).

• OSHA's interpretation "Scaffold and fall protection clarification" (Dec. 5, 2023) confirms that overhead and falling-object protection for suspended scaffolds must comply with 29 CFR 1926.451(h).
• Typical protections addressed by Subpart L include toeboards, debris nets, canopies, and requiring hard hats for workers below—but you must follow the specific measures and thresholds found in 29 CFR 1926 Subpart L.

Yes — a podium ladder that incorporates an elevated platform for employee work meets OSHA's definition of a scaffold and must comply with Subpart L rather than the ladder rules in Subpart X.

• OSHA addressed this in the letter "Podium ladder OSHA coverage" (Dec. 10, 2007) and concluded the pictured device qualifies as a scaffold.
• If the device is on casters, the mobile scaffold requirements such as those referenced in 29 CFR 1926.452(w) (mobile scaffold requirements) would also apply; see 29 CFR 1926 Subpart L for full details.

No — OSHA does not require wooden scaffold planks to be graded and stamped by a lumber grading agency, but employers must ensure the planking meets Subpart L design and load requirements.

• OSHA explained this in the letter "Scaffold plank grading agencies" (Feb. 16, 2001), stating that while Appendix A offers guidance, a grading stamp is not mandatory.
• Employers still must select planking that satisfies the scaffold's design and load demands and may use the non-mandatory Appendix A guidance in 29 CFR 1926 Subpart L to help determine appropriate lumber strength.

A qualified person (the individual responsible for scaffold design and selection) is expected to determine whether wooden planking meets the scaffold's strength and load requirements.

• OSHA's Feb. 16, 2001 letter "Scaffold plank grading agencies" (Feb. 16, 2001) explains that a qualified person should base calculations on recognized grading rules or other acceptable engineering methods when selecting planking.
• See the guidance in 29 CFR 1926 Subpart L and its Appendix A for non-mandatory selection methods and references to lumber grading rules.

No — employers generally cannot rely solely on training videos to meet scaffold-related training obligations because training must be effective, tailored, and sufficient to ensure employees understand the hazards and safe work practices.

• OSHA clarified in the letter "Video training for OSHA compliance" (Aug. 3, 1999) that 1926.21 requires instruction to be effective and site- and task-specific; while not explicitly banning videos, OSHA said video-only programs often fail to provide the necessary site-specific and hands-on training.
• Scaffold employers should use training methods that verify understanding and cover the scaffold hazards and procedures called for in 29 CFR 1926 Subpart L.

Yes — if a podium ladder or similar device is on casters, the mobile scaffold requirements in Subpart L apply in addition to the general scaffold requirements.

• OSHA noted this in the letter "Podium ladder OSHA coverage" (Dec. 10, 2007), which stated that the pictured device on casters must meet the mobile scaffold rules such as those in 29 CFR 1926.452(w) and the broader Subpart L provisions.
• Consult 29 CFR 1926 Subpart L for required mobility and stability controls (e.g., outriggers, wheel locks) applicable to mobile scaffolds.

If a conveyance is treated as a suspended scaffold, fall protection must comply with 29 CFR 1926.451(g) and overhead/falling-object protection must comply with 29 CFR 1926.451(h).

• OSHA expressly stated these obligations in the letter "Scaffold and fall protection clarification" (Dec. 5, 2023).
• See 29 CFR 1926 Subpart L for the full regulatory text of 1926.451(g) and (h) and their options and requirements.

No — OSHA compliance officers are not specially trained to identify scaffold-grade lumber by visual grain or ring patterns; instead they evaluate whether the employer has taken the steps necessary to comply with Subpart L.

• The Feb. 16, 2001 letter "Scaffold plank grading agencies" (Feb. 16, 2001) explains that compliance officers assess whether a qualified person has selected appropriate planking and whether the employer followed the standard—not whether the officer can visually grade lumber.
• Employers should document how planks meet design and load requirements under 29 CFR 1926 Subpart L.

No — OSHA does not treat a "scaffold grade" stamp as a guarantee of safety, and the agency chose not to require a mandatory stamping program because markings alone do not ensure a safe platform.

• OSHA discussed this policy in "Scaffold plank grading agencies" (Feb. 16, 2001), noting that stamping is not required and that markings can create a false sense of security if relied on alone.
• Employers remain responsible for ensuring planks meet the scaffold's design and load demands under 29 CFR 1926 Subpart L.

Employers must take reasonable steps to ascertain that employees understand the scaffold safety training provided — for example by using tailored instruction, demonstrations, hands-on practice, or other checks of comprehension.

• OSHA stated in "Video training for OSHA compliance" (Aug. 3, 1999) that 1926.21 requires effective training that is appropriate to workers' language and education and that employers should verify understanding rather than relying solely on passive video instruction.
• For scaffold work, ensure training covers the hazards, fall protection methods, and procedures required by 29 CFR 1926 Subpart L.

Yes — Appendix A to Subpart L is a non-mandatory guide that employers and qualified persons may use to help select lumber for scaffold planks and to calculate lumber strength.

• OSHA described this guidance and its voluntary nature in "Scaffold plank grading agencies" (Feb. 16, 2001).
• Employers may rely on Appendix A and recognized grading rules or inspection agencies when making strength calculations under 29 CFR 1926 Subpart L.