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.
September 8, 1993
IBRES Export Department
Delta Systems B.P. 20-Z.I.
de Fauillet 47400 TONNEINS (France)
Dear Jean Marc IBRES:
This is in response to your July 23 letter requesting information on the United States safety standards for aerial work platforms. The Occupational Safety and Health Administration (OSHA) does not, at this time, have aerial work platform standards or requirements specific to the operation of aerial work platforms described in the brochures enclosed with your letter. Sections 18.104.22.168 in American National Standards Institute (ANSI)/Scaffold Industry Association (SIA) standard A92.3-1990, Manually Propelled Elevating Aerial Platforms, and 4.12.2, in ANSI/SIA A92.6-1990, Self-Propelled Elevating Work Platforms, are requirements to protect employees from recognized hazards. These ANSI/SIA consensus standards may be referenced by OSHA compliance officers during workplace safety inspections.
Please be advised that French and German safety and health standards are not recognized specifically in OSHA standards. Employers must use products in their workplaces in compliance with OSHA standards. Some products identified in the OSHA standards must be approved, that is, accepted, verified, listed, labelled or otherwise determined to be safe by a nationally recognized testing laboratory (NRTL's). These NRTL's are regulated by OSHA.
Thank you for your interest in occupational safety and health. If we may be of further assistance please contact Ronald Davies, (202) 219-8031, of my staff.
Roger A. Clark, Director
Directorate of Compliance Programs