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.

March 31, 1994

Mr. Craig Firl
DBI/SALA Applications Engineer
D B Industries, Inc.
P.O. Box 46
Red Wing, MN 55066-0046

Dear Mr. Firl:

This is in further response to your June 25 and July 23, 1993 letters, requesting clarification on what Occupational Safety and Health Administration (OSHA) standards apply to a manually operated winch and tripod system used for raising, lowering and supporting employees.

The Agency has determined, based on the information provided, that the applicability of OSHA's scaffold standards to a manually operated winch and tripod system depends on the use to which the system is put. In particular, a winch and tripod system used to suspend an employee for work activities is a single-point adjustable suspension scaffold which must comply with 29 CFR 1910.28 (General Industry) or 29 CFR 1926 [Subpart L] (Construction). OSHA has further determined that this system is not a scaffold when raising or lowering an employee who does not use it for suspended work activities. In that case, the requirements of 1910.28 and 1926 [Subpart L] would not apply. Also, OSHA notes that entrants, does not set performance requirements for retrieval systems. The preamble of the standard does state that a mechanical device used for retrieval of entrants "should be appropriate for rescue service."

The American National Standards Institute (ANSI) may be considering development of a safety standard covering tripod hoist systems. We suggest that you contact ANSI and relate your interest. The Z-359 committee may be ANSI's focal point for such a standard.

We appreciate your interest in occupational safety and health. If we can be of further assistance, please do not hesitate to contact us.


H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs