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.

July 11, 1983

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

Dear Mr. Stafford:

This is in response to your letter of June 25, 1983, concerning requirements contained in OSHA Instruction STD 1-3.3.

In regard to the situations mentioned in your correspondence, automatic rope grabs are not required on platforms where a single attachment point for each employee equipped with a 3 foot lanyard will allow occupants to reach their entire work areas.

A secondary wire rope at each end of a powered platform to ensure that the platform will not fall in the event the main suspension system fails is not equivalent to the type "F" platform. An automatic rope grab is required for such installations. In the event of the main suspension system failing, the secondary system could function improperly or fail.

29 CFR 1910.66(d)(8) allows each employee on the working platform of type T powered platforms to be provided with a safety belt with means for attachment to a lifeline in lieu of the static line attached to the platform. Employers using the lifeline body harness system of employee protection are in compliance with 29 CFR 1910.66 and OSHA Instruction STD 1.3.3.

If you are aware of a State which enforces a requirement for the horizontal static line to be secured approximately every three feet, notify this office and we will attempt to resolve the matter.

I hope this information is helpful to you. If I may be of further assistance, please feel free to contact me.

Sincerely,



John K. Barto
Chief, Division of Occupational
Safety Programming