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OSHA 1910.66AppA

Powered platforms guidelines

Subpart F

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.66 App A, what is the purpose of Appendix A and can employers use alternative methods not shown in the appendix?

Appendix A is advisory and provides examples you can use but it does not add or remove mandatory rules; employers may use other equipment or procedures that meet the mandatory requirements. Employers should rely on the Guidelines in 1910.66 App A for helpful examples, but must still comply with the mandatory provisions of 1910.66.

Under 1910.66 App A, who must provide written assurance that a powered platform installation complies with specific requirements, and who remains responsible for compliance?

The building owner must provide written assurance to the employer that the powered platform installation complies with the listed items in paragraph (c), but the employer remains responsible for meeting any other requirements not covered by that written assurance. See the statement about Assurance in 1910.66 App A and the related 1910.66(c).

Under 1910.66 App A, which nationally recognized standards does OSHA recommend consulting when designing powered platform installations?

Designs should be based on limitations established by nationally recognized standards such as AISC, ANSI, ASME, ASTM, ASCE, AWS, NEMA, and others listed in the appendix. See the list of acceptable standards in Design Requirements in 1910.66 App A and the general requirements in 1910.66.

Under 1910.66 App A, what are acceptable types of tie-in guides and what minimum dimensions should be used?

Indented mullions, T-rails, or equivalent guides are acceptable tie-in guides, and the minimum opening for tie-in guides is 3/4 inch (19 mm) with inside dimensions at least 1 inch (25 mm) deep and 2 inches (50 mm) wide. See the guidance on tie-in guides and dimensions in 1910.66 App A.

Under 1910.66 App A, what hazards are associated with improperly aligned continuous stabilization tie-in guides and what should employers watch for?

Improperly designed or misaligned continuous stabilization guides can cause guide rollers or shoes to jam at track joints, creating a hazard; employers should inspect for extended or discontinuous joints, misaligned rollers, or evidence that rollers will bind. See the warning about alignment and jamming in 1910.66 App A.

Under 1910.66 App A, how should building anchors be selected and spaced for intermittent stabilization systems?

Select and space building anchors based on building height and design, platform length and weight, wire-rope angle, and wind velocities; one acceptable method is vertical rows every third floor or 50 feet (15.3 m), whichever is less. See the Building anchors and intermittent stabilization guidance in 1910.66 App A.

Under 1910.66 App A, what are recommended types and features of stabilizer ties for intermittent stabilization systems?

A stabilizer tie should use a quick-connect/quick-disconnect corrosion-resistant yoke and retainer spring that fits over the building anchor plus a lanyard to keep the suspension rope at a fixed distance from the building; ties should be easy for employees to install and not so long that they entangle with rollers or platform parts. See the description of stabilizer ties in 1910.66 App A.

Under 1910.66 App A, what is the recommended procedure for using stabilizer ties during descent and ascent on an intermittent stabilization system?

During descent, stop at each anchor elevation and have platform occupants attach stabilizer ties to both suspension ropes; during ascent, remove ties at each anchor elevation—platform stopping devices should interrupt hoist power if a stabilizer is contacted on ascent to ensure removal. See the procedural guidance for intermittent stabilization in 1910.66 App A.

Under 1910.66 App A, how often and why should suspension wire rope be inspected and when must it be replaced?

Suspension wire rope should be inspected regularly because it loses strength over its life; if there is any doubt about a rope's integrity or ability to carry the required design factor it must be replaced. Appendix A emphasizes using an experienced rope inspector and replacing rope with any sign of core degradation or valley breaks; see Wire Rope Inspection in 1910.66 App A and the maintenance obligations in 1910.66(h).

Under 1910.66 App A, what routine maintenance items should an employer perform to meet general maintenance requirements?

Employers should promptly replace broken, worn, or damaged parts, switch contacts, brushes, short flexible conductors, damaged electrical components, and significantly abraded traveling cables; keep gears, shafts, bearings, brakes and hoisting drums in proper alignment. See General Maintenance guidance in 1910.66 App A and the related 1910.66(h)(1).

Under 1910.66 App A and 1910.66(i)(1), what should powered-platform training include and how should competency be verified?

Training should include both classroom and on-the-job instruction, written procedures (from the manufacturer if possible), hands-on practice, inspection and use of personal fall protection required by 1910.66(j)(1), and emergency action planning; after training, employees must demonstrate competency in safe operation. See the Training guidance in 1910.66 App A and the training requirement in 1910.66(i)(1).

Under 1910.66 App A, when should supplemental training be provided and what additional training is required when chemicals are used on a platform?

Supplemental training must be given whenever equipment or working conditions change; employees using chemical products on platforms must be trained in safe cleaning procedures, hazards and handling of those chemicals, and be supplied appropriate PPE such as gloves and eye/face protection. See the supplemental training and chemical-handling guidance in 1910.66 App A.

Under 1910.66 App A, what records or written procedures should employers obtain or prepare for powered platform operation and maintenance?

Employers should obtain the manufacturer's written procedures when possible or prepare written operating, inspection, maintenance, and emergency procedures for employee use; these form the basis of training and safe work practices per the guidance in 1910.66 App A and the training requirements in 1910.66(i)(1).

Under 1910.66 App A and 1910.66(e)(2)(iii), how can an employer demonstrate that an alternative suspension or securing method is equivalent to a method specified by the standard?

An employer can demonstrate equivalency by providing an engineering analysis prepared by a registered professional engineer showing the alternative provides an equal or greater degree of safety than the methods specified in the standard. Appendix A states this as an acceptable method for complying with equivalency requirements in 1910.66(e)(2)(iii) and related provisions. See 1910.66 App A.

Under 1910.66 App A, what factors should be considered when selecting the vertical distance between building anchors used for intermittent stabilization?

Consider building height and architectural design, platform length and weight, wire rope angulation, and local wind velocities when choosing vertical anchor spacing so the anchors properly limit horizontal platform movement. See the anchor-spacing guidance in 1910.66 App A.

Under 1910.66 App A, how should indented anchor receptacles in a building façade be maintained?

Indented anchor receptacles should be kept clear of debris and extraneous materials that would hinder use, and any evidence of anchor failure or abuse should be reported to the employer during inspections. See the anchor maintenance guidance in 1910.66 App A.

Under 1910.66 App A, what should employers do if wire rope shows signs of end termination degradation or valley breaks?

Employers should cut off degraded rope end sections or replace the rope before failure, because small repairs or delaying replacement risks sudden rope failure; Appendix A emphasizes preventive maintenance and timely rope replacement. See Wire Rope Inspection guidance in 1910.66 App A and maintenance duties in 1910.66(h)(1).

Under 1910.66 App A and 1910.66(f)(5)(i)(F), what is an acceptable way to show a new method of suspending or securing a platform is equally safe?

One acceptable way is to provide an engineering analysis by a registered professional engineer demonstrating the proposed method provides equal or greater employee safety than the listed methods; Appendix A specifically notes that an RPE analysis meets the equivalency requirement in 1910.66(f)(5)(i)(F). See 1910.66 App A.

Under 1910.66 App A, who should inspect powered-platform anchors and what should they look for?

A competent person should inspect anchors during platform installation and periodic checks for failures, corrosion, deformation, loosening, or abuse, and report any problems to the employer for prompt correction. See the anchor inspection guidance in 1910.66 App A and the owner's assurance responsibilities in 1910.66(c).

Under 1910.66 App A and the head-protection Letter of Interpretation (June 6, 2024), are powered-platform occupants required to wear hard hats when there is an overhead hazard?

Yes—if platform workers are exposed to overhead falling-object hazards, employers must provide and require head protection that meets consensus standards; see 1910.66 App A and the head protection interpretation explaining 29 CFR 1910.135 requirements.

Under 1910.66 App A and the fall-protection Letter of Interpretation (June 6, 2024), how should employers think about fall protection training and systems for platform work?

Employers must train workers on inspection, care, and use of required personal fall protection systems and provide fall-protection measures appropriate to the work; Appendix A requires training on fall protection in 1910.66(j)(1) and the interpretation about fall protection reinforces that employers must assess hazards and provide needed protection (fall protection letter).

Under 1910.66 App A, what emergency planning elements should be included in powered-platform training?

Training should include an emergency action plan (rescue and evacuation) and familiarization with procedures such as those summarized in OSHA’s brochure; Appendix A specifically recommends emergency planning as part of the 1910.66(i)(1) training program and refers to OSHA emergency planning resources in 1910.66 App A.