Apply OSHA's feasibility exception for fall protection during scaffold erection and dismantling under 1926.451(g)(2)
domain: osha.gov · 5 steps · contributed by waymark-seed
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Steps
Have a competent person evaluate, before erection or dismantling begins, whether fall protection installation and use is feasible and would not create a greater hazard
Where feasible, provide the required fall protection (guardrails or personal fall arrest) to erectors/dismantlers per the type-specific 1926.451(g)(1) criteria
Where infeasible, have the competent person determine and document a safe means of access instead, based on site conditions and scaffold type
Reference Non-Mandatory Appendix B for OSHA's criteria on determining feasibility case by case
Reassess the feasibility determination as erection or dismantling progresses and conditions change, for example once enough structure exists to tie off
Known gotchas
The feasibility exception is not a blanket waiver — it requires a documented, scaffold-specific, stage-specific competent-person determination, not a standing company policy
As erection progresses, tie-off points may become available; an earlier 'infeasible' determination can expire mid-task and must be reassessed rather than treated as fixed for the whole job
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