Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

July 16, 1985

Mr. Arnold Lever
Finda's Hotel
84 Bury Old Road
Manchester 8

Dear Mr. Lever:

Thank you for your letter of July 1 to the Assistant Secretary for Occupational Safety and Health (OSHA) regarding safety standards for window cleaners and workers in refridgeration plants.

OSHA does not have specific safety standards for window cleaners. However, OSHA does have safety standards which require compliance by employers in the use of two point suspension scaffolds (swinging scaffolds) (29 CFR 1910.28) and powered platforms (29 CFR 1910.66) which may be used for window cleaning. These two standards are part of OSHA's General Industry Standards (pages 45 and 63), which are enclosed for your use.

In reviewing the contents of OSHA's General Industry Standards, you will note that OSHA does not have specific safety standards which address hazards faced by workers in refridgeration plants. However, there are several portions of the standards which may be of special interest to you, including the following:

Section Title and Page:

Subpart Title and Page:

In addition, you may wish to obtain a copy of an industry standard on window cleaning (ANSI A39.1-1969) from the American National Standards Institute, 1430 Broadway, New York, N.Y. 10018 at a cost of $6.00. This standard is not a mandatory safety regulation requiring compliance by employers, but is a voluntary standard adopted by the industry.

We appreciate your concern and effort in helping to achieve a safe workplace for employees in these industries.



Barry J. White, Director
[Directorate of Standards and Guidance]


[Corrected 2/6/2004]

July 1, 1985

Dear Secretary,

I am sorry to bother you, but would be very grateful for your help.

I am an English Solicitor, retired, who, of recent years, have become interested in Safety Codes, and am glad to say that I have been able to be in touch with our English Health and Welfare Office here in Manchester in these matters.

I have, in reading a very illuminating and inspiring article by Professor Willis Woolsey of Texas University, it came to my mind that in two departments of Safety Codes, at any rate, the experience of your country vastly exceeds that of any other nation, namely:

  1. Safety Codes for Window-Cleaner (This particularly applies to those who clean windows at heights)
  2. Safety Codes for workers in Refrigeration Plants

Following on that, I felt that a study of The American Codes for Safety in these two departments might well be of great benefit to workers in this country.

I, accordingly, wrote in that sense to the Secretary of the American Embassy in London, and Mr. Stephen Roberts, the Director of the Reference Center at the Embassy, was so very kind as to write me referring me to yourself, and your Board of the Department of Labor.

I would be very grateful, consequently, if copies of the American Safety Codes for workers in these two departments could be made available to me.

I feel the matter is important because these two departments are truly integral to our lives, and that the benefit of the very extensive experience of our country in ACM could only be of the greatest advantage to workers in this country.

I would be very grateful to hear from you at your convenience, and with very many thanks for your kind consideration.

God Bless

Arnold Lever