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.

August 9, 1996

Mr. Stanley Gitelson
Extra Clean, Inc.
4336 Montgomery Avenue
Lower Level
Bethesda, MD 20814-4402

Dear Mr. Gitelson:

This is in response to your undated memorandum received by facsimile transmittal on August 6. Your questions and our replies follow:

Question 1: As it concerns temporary installations for power scaffolding (swing stage) or window cleaning: single person boatswain's chairs (Sky Genie's), what is the OSHA requirement for certification (meeting certain pre-use criteria) for building roof anchor points?

Reply: The Occupational Safety and Health Administration standard, 29 CFR 1910.28 Safety requirements for scaffolding applies to the scaffolding application you described. Under paragraph 1910.28(a)(28), scaffolds must be secured to permanent structures, through the use of anchor bolts, reveal bolts or other equivalent means. Window cleaners' anchor bolts shall not be used. Also, under paragraph 1910.28(a)(2), the anchorage for scaffolds must be sound, rigid and capable of carrying the maximum intended load without settling or displacement. The employer of workers who use the temporary scaffolding installation you described is responsible for ensuring that the aforementioned scaffolding requirements are met.

Question 2: What is the "Certificate of Regulation Compliance Building" form, attached to my memorandum, from the structural (registered professional) engineer referencing, and is that reference an annual (or any frequency) OSHA requirement?

Reply: The "Certificate of Regulation Compliance Building" attached to your memorandum references 29 CFR. 1910.66 Powered platforms for building maintenance. This standard covers powered platform installations permanently dedicated to building maintenance.

Under paragraph 1910.66(g)(2), building support structures covered, by paragraph 1910.66(e) must undergo periodic inspection by a competent person at intervals not exceeding 12 months. Under paragraph 1910.66(d) Definitions, competent person means a person because of training and experience, is capable of identifying hazardous or dangerous conditions in powered platform installations and of training employees to identify such conditions.

Thank you for your interest in employee safety and health. If we can be of further assistance, please contact Mr. Ronald J. Davies of my staff, telephone (202) 219-8031, extension 110.


Raymond E. Donnelly, Director
Office of Safety Compliance Assistance