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 8, 1993

Ms. Angela Wynn
Contract Specialist
General Services Administration
Federal Supply Service
Washington, DC 20406

Dear Ms. Wynn:

Thank you for your letter of May 28, addressed to Mr. Roy Resnick, requesting a determination of ". . . the need for a UL rating or approval on sweeper/scrubber equipment."

Your initial question was whether sweeper/scrubber equipment would be regulated under the Occupational Safety and Health Administration's (OSHA) General Industry Standard for powered industrial trucks, section 1910.178. OSHA has determined that this type of equipment is not classified as a powered industrial truck and, therefore, need not meet any requirements for section 1910.178.

There are no OSHA requirements for any of the various power- option models of sweeper/scrubbers to be certified as an entity. However, there are circumstances where elements of a sweeper/scrubber require certification by a Nationally Recognized Testing Laboratory (NRTL). (Please see the enclosures for the definition and requirements for an NRTL; the OSHA recognition process for NRTLs; and the latest list of accredited NRTLs). The certification requirements are as follows:

A. Non-Hazardous (Non-Classified) Environments

1. For battery-operated models, the battery chargers must be certified by an NRTL whether they are built-in or supplied separately.

2. For liquefied petroleum gas (LPG)-operated models, there are specific requirements for NRTL certification, as marked on the enclosed copy of OSHA's section 1910.110(e) - Liquefied petroleum gas as a motor fuel.

B. Hazardous or Potentially Hazardous (Classified) Environments

1. For battery-operated models, in addition to the requirements of A.1. above, the motors must be certified by an NRTL for use under the appropriate classification.

2. The requirements for NRTL certification of LPG-powered models remain the same.

Finally, even in those instances where OSHA does not require certification, if sweeper/scrubbers are intended for use in classified locations, they should always be rated for use under the appropriate classification.

Should you have any further questions, please feel free to contact either Hank Woodcock at (202) 219-7065, or Roy Resnick at (202) 219-7193.


Patricia K. Clark
Directorate of Technical Support


May 28, 1993

Mr. Roy Resnick
Department of Labor, OSHA
Office of Variance Determination
Room N3653
200 Constitution Ave. NW
Washington, DC 20210

Dear Mr. Resnick:

I am writing to you with regard to the Code of Federal Regulations No. 29 Part 1910.178.

An issue has arisen among many of my contractors on Schedule 38 I A, Road Clearing and Cleaning Equipment as to the need for a UL rating or approval on sweeper/scrubber equipment. According to the CFR 29 1910.178, it discusses powered industrial trucks in addition to "other specialized industrial trucks". Are sweepers considered under this classification? If not, under what conditions does OSHA consider approval necessary for this type of equipment. If you have any information that would clarify this matter I would greatly appreciate it.

Should you have any questions, please call at (703) 308-4166.


Angela Wynn
Contract Specialist