Roof perimeter protection and powered platform inspections

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 13, 1987

Mr. Lawrence R. Stafford
Stetson - Harza
[Recipient address omitted]
Dear Mr. Stafford:

This is in response to your letters of July 30, 1987, concerning perimeter protection along roofs and the necessary inspection cycle required by 29 CFR 1910.66(e)(3).

The Occupational Safety and Health Administration (OSHA) standards at 29 CFR 1910.23 are applicable to all workplaces and do not exempt old installations. Employers are required to provide perimeter protection or fall protection for all employees exposed to hazardous falls from height, such as from roofs. The enclosed OSHA Instruction STD 1-1.13 clarifies the requirements for fall protection in general industry situations.

In regard to your concern for the inspection requirements of powered platforms for exterior building servicing as specified by 29 CFR 1910.66(d)(3), we provide the following clarification. Periodic inspections and tests need not be conducted on 30 day intervals when the intended usage of the equipment is less frequent than every 30 days. However, the equipment must be placarded as required by 29 CFR 1910.145(c)(3), instructing potential users that the equipment must be inspected and tested as required by applicable portions of 29 CFR 1910.66(e) prior to each use. Furthermore, the equipment should be locked-out so that occasional unsupervised use is impossible. Employers who comply with such a placarded instruction, and lockout procedure, although in technical violation of the standard, would not create a hazard for employees and would not be subject to citation under the rules for a de minimis violation. De minimis violations are discussed by an enclosure.

Dormant equipment which is not available for use by employees can not be hazardous or in violation of the Occupational Safety and Health Act.

If we may be of further assistance, please contact us.

Sincerely,

Leo Carey, Director
Directorate of Field Operations

[Requester letter reproduced on OSHA page; omitted here.]