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.

November 22, 1991

Mr. Delmar Dahl
Manager, Technical Services
American Test Center
3540 Hoffman Road East
St. Paul, Minnesota 55110

Dear Mr. Dahl

This is in response to your letter of October 2, addressed to Mr. Ray Donnelly, Director of the Office of General Industry Compliance Assistance. The question posed in your letter and the corresponding reply follow.

Question:

Does the Nationally Recognized Testing Laboratory (NRTL) program apply to companies that perform in-service inspections of fire department aerial apparatus and ground ladders?

Reply:

The OSHA standards do not require "approved" aerial apparatus and ground ladders. Therefore, NRTL certification of this equipment is not required.

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

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs




October 2, 1991

Mr. Raymond Donnelly, Dir.
Office of General Industry Compliance Assistance
US/DOL/OSHA
200 Constitution Avenue, NW Room N3119
Washington D.C. 20210

Dear Mr. Donnelly:

In preparing a bid for annual in-service inspections of fire department aerial apparatus and ground ladders, a customer indicated in the specifications that the," Bidder shall be a nationally recognized testing laboratory recognized by (OSHA in accordance with the OSHA regulations set forth in 29 Code of Federal Regulations, Section 1910.7, Appendix A, "OSHA Recognition Process for Nationally Testing Laboratories, NO EXCEPTIONS."

I respectfully request your opinion on the following question:

 

a) Does the NRTL program apply to companies that perform annual in-service inspections of fire department aerial apparatus and ground ladders?

Thank you for taking time to read my letter. If you have any questions please call me toll free at 800-451-9087.

Sincerely,



Delmar Dahl
Mgr. Tech. Services