- Standard Number:
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.
January 18, 1983
| MEMORANDUM FOR: | JAMES W. LAKE REGIONAL ADMINISTRATOR |
| THRU: | JOHN B. MILES, JR. DIRECTOR, OFFICE OF FIELD COORDINATION |
| FROM: | PATRICK R. TYSON DIRECTOR, FEDERAL COMPLIANCE AND STATE PROGRAMS |
| SUBJECT: | OSHA Instruction STD 1-33: "Building Anchors Used for Intermittent Stabilization of a Suspended Powered Platform in Window Washing Operations and Light Building Maintenance" |
| REFERENCE: | Region VIII's Memorandum dated November 18, 1982, concerning subject Instruction |
29 CFR 1910.66(b)(3) requires T-rails, indented mullions, or equivalent guides located in the face of the building, if provided, shall be maintained in proper working order so that they perform the function for which they are intended. OSHA Instruction STD 1-3.3 does not change the above standard, but recognizes an equivalent system which employers may utilize for window washing operations and light building maintenance on new buildings or in the retrofitting of existing buildings.
The clarification was necessary because on some structures it is not practical to install building face guiding members as specified in 29 CFR 1910.66(b)(3) and it was determined that the intermittent stabilization system provides equivalent employee protection and the employer has the option of selecting either system. Under the Instruction, neither OSHA nor the employer are obligated to prove that building face guiding members are not available for safe operation of suspended powered platforms, the instruction provides for an acceptable safe alternative.
Window cleaner service contractors are not being forced, or allowed by OSHA, to utilize a Suspended Powered Platform which is hazardous to employees. In some ways the intermittent stabilization system provides more safety for exposed employees than the existing standard. We would appreciate receiving any information regarding hazardous working conditions relative to these systems. As an alternative, the instruction requires employers to provide a body harness in place of a safety belt, with its lanyard attached to a 5/16 inch diameter horizontal galvanized wire rope static line. In accordance with 29 CFR 1910.66(d)(8), employers may provide independent lifelines, in lieu of the static line for employees. However, this in not always a better method. Long lifelines may result in a safety hazard to employees on a windy day. Wind forces upon a long lifeline could pull an employee from a scaffold. As you can see, the instruction allows either procedure to be used. 29 CFR 1910.66(e)(5) and (e)(9) shall be cited when employers do not meet the requirements of the standard or of the alternative procedures permitted under OSHA Instruction STD 1-3.3.