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.

June 2, 1992

Mark Diehl
Project Manager
Powered Platforms Mfg.
35305 Glendale
Livonia, Michigan 48150

Dear Mr. Diehl:

This is in response to your letter of March 25 to Ms. Linda R. Anku, Regional Administrator for Region III of the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Compliance Programs in OSHA for response.

In your letter you requested OSHA's comments on the design and use of the tie-in system intended for use as part of a power platform installation permanently dedicated to building maintenance which is subject to compliance with OSHA standards at 29 CFR 1910.66. Further, you indicate that the tie-in system does not employ standard intermittent stabilization anchors. Also, you related the building owner's concern that the OSHA standards at 29 CFR 1910.66, which do not permit the use of an intermittent tie-in system to accomplish lateral movement across the building face, may be applicable to the tie-in system installed on his building.

By 1910.66(e)(2)(iv), tie-in guides are required for building interiors (atriums) except when a registered professional engineer determines that an alternative stabilization system, including the intermittent stabilizations system, the button guide stabilization system and the system utilizing angulated roping and building face rollers in 1910.66(e)(2)(iii)(A), (B) and (C) respectively, or a platform tie-off at each work station will provide equivalent safety. In order to be in compliance with 1910.66(e)(1)(i), the alternative stabilization system described in your letter must be designed by or under the direction of a registered professional engineer experienced in such design.

By 1910.66(c)(1), building owners are required to assure employers, that new installations meet the requirements of paragraphs 1910.66(e)(1) and (f)(1) and additional design criteria, including criteria for the stabilization system, in other 1910.66(e) and (f) provisions before each use by employees. In accordance with 1910.66(c)(2), this assurance shall be based on relevant available information including verification by a registered professional engineer.

The blueprints forwarded by your letter are enclosed for your further use. We appreciate your interest in occupational safety and health. If we can be of further assistance, please do not hesitate to contact us.


Patricia K. Clark, Director
Directorate of Compliance Programs