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Testing of single-point suspension scaffold winches

Summary A scaffold equipment maker asked whether manually operated winches tested by a laboratory other than the two named in OSHA’s rules could be used. OSHA said the arrangement described appeared to be a de minimis violation, which inspectors would document without a citation or abatement requirement. OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1986-09-05
Date issued
September 5, 1986
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 OSHA 1926 Scaffolds
Source
View the official document

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The current status of this document is unclear
OSHA archives this letter and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 5, 1986

Mr. J. Thomas Wolner
R & D Engineer
D B Industries, Inc.
[Recipient address omitted]
Dear Mr. Wolner:

This is in response to your letter of August 20, 1986, concerning in Occupational Safety and Health Administration's (OSHA) testing requirements for the power units or manually operated winches of single-point adjustable suspension scaffolds.

29 CFR 1910.28(i)(1) and 29 CFR 1926.451(k)(1) both require the scaffolding, includes power units or manually operated winches, shall be of a type tested and listed by Underwriters' Laboratories or Factory Mutual Engineering Corporation.

It appears based on the information you provide this Agency that manual winches tested per U.L. Standards by Twin City Testing would be a de minimis violation of the above mentioned standard. De minimis violations are violations of standards which have no direct immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way any other violation but are not included on the citation. Abatement is not required of de minimis violations.

If we can be of further assistance, please let us know.

Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

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