However, since my students like to see clarifications in black and white, I would appreciate a written response from your office. Several compliance officers I have discussed this with have indicated that they are in agreement and might even use 1926.200(h)(1) for a citation if the situation warranted. Consequently, a warning tag should be used. Therefore, it would be a hazard and fall under the defective equipment category until the scaffold is completed and all safety features installed. A partially erected scaffold may not have guardrails, or ladders, and be properly tied or be fully planked. 200(h)(1) requires warning tags to be placed on any existing hazard such as a defective tool or equipment. Many students ask me, "Is this required by OSHA?" This is a widely accepted practice in industrial plants and tagging systems (including warning tags) are available from a variety of sources. My recommendations to our students is that a warning tag be placed on the scaffold while it is being erected because it is only partially complete and may not have all appropriate safety features installed.Īfter the scaffold is complete and final inspection is done, I recommend that a green "OK" tag or some other type of sign off sheet be placed on the scaffold to indicate that it is ready for use. One of the issues that frequently comes up in class is that of putting a tag on the scaffold. I teach courses in Scaffolding Safety to various contractors, industrial plants and other scaffolding users. I am writing to introduce myself and ask for a clarification on an issue. If you have further questions, please contact of my staff in the office of Construction and Maritime Compliance Assistance at. I believe this is what the compliance officers meant when they indicated to you that they are in agreement and "might even use 200(h)(1) for a citation if the situation warranted". A tag which limits access to erection and disassembly crews on that portion of a scaffold being changed could be appropriate but a case by case determination is necessary. An example of the latter is where a large scaffold is being built in phases or sections, employee access to the completed sections of the scaffold would not be prohibited. Relate this incident or, better, one you know. 200(h)(1) could be issued, there are also many instances where such would not be appropriate. fully planked, use of baker scaffolds, fall protection, power lines, workers on guard rails. Although there are instances where such tags are appropriate and a citation under. Presently, there is no requirement that warning tags be placed on all scaffolds while they are being erected. I apologize for the delay of this response. This is in response to your April 6 letter requesting a clarification of the Occupational Safety and Health Administration policy for warning tags on scaffolds.
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