OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

August 25, 1975

Mr. K. M. Stead
Regional Manager
The Equitable Life Assurance
Society of the United States
1285 Avenue of the Americas
New York, New York 10019

Dear Mr. Stead:

This is in response to your letter dated July 28, 1975, concerning certain inspections required by Section 1910.66(e)(3) Powered Platforms for Exterior Building Maintenance, of the Occupational Safety and Health Standards.

You have questioned the requirement for a 30 day inspection and test contained in the above standard as it pertains to a powered platform used by the Gem Window Cleaning Company of New York.

The requirements of the standard are, in part, that each installation undergo a maintenance inspection and test every 30 days except where the cleaning cycle is less than 30 days such inspection and test shall be made prior to each cleaning cycle. The powered platform referred to in our June 6, 1975 letter is used only on a 120 day cleaning cycle. It is placed in storage and locked up between these cycles. In this instance the required inspection and test must be conducted and documented prior to the start of the next cleaning cycle.

For the purpose of clarification, a powered platform in use shall undergo a maintenance inspection and test every 30 days except where the cleaning cycle is less than 30 days, such inspection and test shall be made prior to each cleaning cycle. With respect to non-use (in storage, undergoing repairs, etc.) a 30 day maintenance inspection and test would not be required.

If I can be of further service, please contact me.

Sincerely,



Bert M. Concklin
Deputy Assistant Secretary