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 https://www.osha.gov.

Apr 15, 1985

Mr. James R. Wallin
General Electric Company
Gas Turbine Division, Building 53 Room 107
One River Road
Schenectady, New York 12345

Dear Mr. Wallin:

This is in response to your letter of March 12, 1985, in which you request our opinion of which Occupational Safety and Health Administration (OSHA) standard is applicable to the manually propelled elevating work platform described by your figure.

The device described by your figure (copy enclosed) appears to be an adjustable mobile work platform within the stated scope of ANSI A92.3-1980. It is not within the scope of 29 CFR 1910.29, which was adopted from ANSI A92.1-1971. Therefore, no specific OSHA standard pertains to this particular type of equipment. Hazardous conditions involving the use of such equipment at the worksite are regulated by the general duty clause, Section 5(a)(1) of the OSH Act. Adjustable mobile work platforms meeting the requirements of ANSI A92.3-1980 would not be in violation of the Act.

If we may be of further assistance, please contact us.


John B. Miles, Jr., Director
Directorate of Field Operations


Enclosure is illustration of an adjustable mobile work platform