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.

July 5, 1995

Mr. Kevin Crocker
CCH Incorporated
Industrial Law Department
One Thorndale Drive, CS-4900
San Rafael, California 94903

Dear Mr. Crocker:

This is in response to your January 18 letter requesting an interpretation of the Occupational Safety and Health Administration standard 29 CFR 1910.66, Powered platforms for building maintenance. I apologize for the delay in responding to your inquiry.

With regard to whether existing installations completed before 1990 are covered by §1910.66(c)(3), please be advised that paragraph (c)(3) applies to building owners of all new and existing installations. Paragraphs (c)(1) and (c)(2) are, applicable only to new installations, and to existing installations following any major modifications completed after July 23, 1990.

With regard to Appendix D, please note that the appendix does not delineate which parts of paragraph (c), such as (c)(1) and (c)(2), are exempt for installations completed after August 27, 1971, but no later than July 23, 1990.

Thank you for your interest in employee safety and health. If we can be of any further assistance, please contact Mr. Wil Epps of my staff at (202) 219-8041.


Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance

January 18, 1995

Raymond Donnelly, Director
Office of General Industry Compliance Assistance
Third and Constitution Ave. NW
Washington, DC 20210

Dear Mr. Donnelly:

My company, CCH Incorporated, publishes the EMPLOYMENT SAFETY AND HEALTH GUIDE, a weekly reference service devoted to current development in the area of occupational safety and health law.

As part of our continuing analysis of the OSHA standards, our editors have discovered the following problems in 29 CFR 1910.66, Powered Platforms for Building Maintenance:

According to 1910.66(b)(2), "existing installations" built before 1990 are required to comply with paragraphs (g) through (j) of 1910.66, plus Appendices C and D. Yet, according to paragraph (c)(3) "building owners" of "new and existing installations" must inform the employer that the installation has been inspected and properly maintained. Also, the first sentence of Appendix D states that installations completed between 1971 and 1990 are exempt from a number of paragraphs, including paragraph (c).

The question is: are existing installations completed before 1990 covered by paragraph (c)(3), or not?

Your prompt attention to the above matter would be greatly appreciated.

My mailing address is:


CCH Incorporated
Attn: Kevin Crocker
Industrial Law Department
One Thorndale Drive, CS-4900
San Rafael, CA 94903

Very truly yours,


Kevin Crocker
Senior Writer/Analyst
Industrial Law Department