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.

May 21, 1982

Mr. Kenneth C. Miller
General Manager
United States Window Cleaning
1424 K Street, NW, 4th Floor
Washington, D.C. 20005

Dear Mr. Miller:

This is in response to your letter of May 11, 1982, requesting a clarification on window cleaning operations.

The Occupational Safety and Health Administration does not prohibit the use of boatswain's chairs for window cleaning purposes. However, the American National Standards Institute's ANSI A39.1-1969, a national consensus standard which was developed to provide safety requirements for window cleaning work makes the following recommendation. Boatswain's chairs shall be used for window cleaning operations only where the windows cannot be cleaned safely and practically by other means. Powered platforms and swinging scaffolds allow employees to stand upright, protected with guardrails and the platforms are stabilized against the building, for the additional safety of employees.

Based on the information provided in your letter, it appears the offsetting of the suspension system at the canopy may be in violation of 29 CFR 1910.28(a)(5), because it would appear to place additional stress on the suspension cables and motors of the scaffolding as indicated in your letter.

Employers finding it necessary to use boatswain chairs for window washing operations shall ensure that equipment used complies with all of the requirements contained in 29 CFR 1910.28(j) for boatswain's chairs.

If I may be of further assistance, please feel free to contact me.

Sincerely,



John K. Bart
Chief, Division of Occupational
Safety Programing