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.

December 15, 1992

Mr. Stefan D. Bright,
Chairman Safety and Training Standards Committee
International Window Cleaning Association
P.O. Box 48428
Niles, Illinois 60648

Dear Mr. Bright:

This is in response to your September 15, letter to Ms. Patricia K. Clark, former Director of the Directorate of Compliance Programs. In your letter you requested clarification on the applicability of OSHA's standard at 29 CFR 1910.66 on powered platforms for building maintenance to "a permanently installed suspended scaffold." We apologize for the delay in responding.

Please note by the definition in 1910.66(d) that a "suspended scaffold" means a scaffold supported on wire or other ropes, used for work on, or providing access to, vertical sides of structures on a temporary basis. The scope of the powered platforms for building maintenance standard (See: 1910.66(a)) does not apply to suspended scaffolds (swinging scaffolds).

The standard at 1910.66(g)(2) requires that a competent person perform periodic inspections and testing of powered platforms permanently dedicated to building maintenance. By the definition in 1910.66(d), a competent person means a person who, because of training and experience, is capable of identifying hazardous and dangerous condition in powered platform installations. The building owner's assurance required by 1910.66(c)(1) shall be based, in part, on these periodic inspections and tests in compliance with 1910.66(c)(2).

Thank you for your interest in occupational safety and health. If we may be of further assistance please contact us.


Roger A. Clark,
Directorate of Compliance Programs