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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 5, 1986

Mr. J. Thomas Wolner
R & D Engineer
D B Industries, Inc.
Post Office Box 46
Red Wing, Minnesota 55066

Dear Mr. Wolner:

This is in response to your letter of August 20, 1986, concerning in Occupational Safety and Health Administration's (OSHA) testing requirements for the power units or manually operated winches of single-point adjustable suspension scaffolds.

29 CFR 1910.28(i)(1) and 29 CFR 1926.451(k)(1) both require the scaffolding, includes power units or manually operated winches, shall be of a type tested and listed by Underwriters' Laboratories or Factory Mutual Engineering Corporation.

It appears based on the information you provide this Agency that manual winches tested per U.L. Standards by Twin City Testing would be a de minimis violation of the above mentioned standard. De minimis violations are violations of standards which have no direct immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way any other violation but are not included on the citation. Abatement is not required of de minimis violations.

If we can be of further assistance, please let us know.


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