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.

June 19, 1981

Lawrence R. Stafford, P.E.
Consulting Engineer
8 Gracemore Street
Albany, New York 12203

Dear Mr. Stafford:

This is in response to your recent inquiry regarding a proposed exterior building maintenance program.

My response to your two questions are as follows:

(1) 29 CFR 1910.66 establishes safety requirements for the design construction, installation, operation, maintenance inspection, and use of power operated platforms for exterior building maintenance. It does not address the condition of a building owner providing the means of suspension and means of guidance for a powered working platform, but not the platform itself. The Powered Platform standards for exterior building maintenance will be enforced on the employer of the employees regardless of the ownership of different pieces of powered platform equipment as defined in 29 CFR 1910.66(a).

(2) ANSI-A-120 13.8.3 requires where building guides are not used, the platform shall have building face rollers and angulated roping. Such working platforms shall exert a minimum pressure of 30 pounds against the side of the building at any position under all conditions of loading. An exception allowing lesser pressure, but in no case less than 10 pounds, is acceptable where workers are provided with safety belts and lifelines in accordance with section 28 of that ANSI standard. OSHA enforces the above mentioned standard for powered platforms as it is written. Additional design criteria for components of the system is necessary before a final decision is made on the proposed traveling track method of compliance. However, the concept appears to comply with the standard if adequate controls are designed into the system.

If we may be of further assistance, please feel free to call or write.

Sincerely,



John K. Barto Chief,
Division of Occupational Safety Programming