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OSHA 1910.66AppB

Platform stabilization system exhibits

Subpart F

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.66AppB, are the three drawings in Appendix B mandatory design requirements for platform stabilization systems?

No — the three drawings in 1910.66AppB are advisory illustrations and are not mandatory design requirements. Appendix B explicitly says the drawings "are to be used for reference purposes only, and do not illustrate all the mandatory requirements for each system." Follow the mandatory rules in 1910.66 and any applicable manufacturer specifications or engineering documentation rather than relying solely on the appendix figures.

Under 1910.66AppB, can an employer rely solely on an Appendix B figure to demonstrate compliance when an OSHA inspector evaluates a platform stabilization system?

No — an employer cannot rely solely on an Appendix B figure to show compliance. The appendix figures are reference examples only and do not replace the mandatory requirements in 1910.66 that govern design, installation, and safe operation. OSHA compliance and inspections are based on the actual mandatory standard text and applicable interpretations, not the advisory drawings in 1910.66AppB.

Under 1910.66AppB, if an Appendix B drawing appears to conflict with a specific provision of 1910.66, which should I follow?

Follow the mandatory regulatory text in 1910.66 — the appendix is advisory only. Appendix B states the figures "do not illustrate all the mandatory requirements for each system," so the regulatory requirements in the standard control when there is any conflict. Use the appendix drawings only as illustrative examples and document how the installed system meets the specific mandatory provisions of 1910.66.

Under 1910.66AppB, do the three figures in Appendix B show all acceptable methods for stabilizing powered platforms?

No — the three figures are examples of typical systems but do not show all acceptable methods. Appendix B says the drawings "illustrate typical platform stabilization systems" and are for reference only, which means other properly designed and compliant stabilization methods may be acceptable provided they meet the mandatory requirements in 1910.66 and any applicable engineering or manufacturer requirements.

Under 1910.66AppB, are specific dimensions or tie-in intervals for the intermittent tie-in system (Figure 2) specified in the appendix drawings?

No — Appendix B does not provide mandatory dimensions or specified tie-in intervals for the intermittent tie-in system. The appendix figures are illustrative and "do not illustrate all the mandatory requirements for each system." Employers must follow the detailed requirements in 1910.66, manufacturer instructions, and any site-specific engineering analysis to determine appropriate tie-in spacing and dimensions.

Under 1910.66AppB, can a building owner use the continuous external mullion guide system shown in Figure 1 on any façade without additional evaluation?

No — you cannot assume the continuous external mullion guide system in Figure 1 is suitable for every façade without evaluation. Appendix B provides a reference illustration only; it does not address building-specific structural capacity, mullion detail, wind loads, or attachment requirements. Employers and owners must ensure any stabilization system complies with the mandatory requirements in 1910.66 and should obtain engineering review or manufacturer certification appropriate to the building and loads.

Under 1910.66AppB, do the Appendix B drawings relieve employers from performing a hazard assessment or engineering review before installing a platform stabilization system?

No — the appendix drawings do not relieve employers from performing required hazard assessments or engineering reviews. Appendix B is advisory and "do not illustrate all the mandatory requirements for each system," so employers must still satisfy the performance, design, and safety requirements in 1910.66 and may need competent-person or engineering evaluations based on system complexity and site conditions.

Under 1910.66AppB, may training materials use the Appendix B figures to teach workers about platform stabilization systems?

Yes — you may use the Appendix B figures as visual examples in training, but you must make clear they are illustrative and not complete design documents. Appendix B states the drawings "are to be used for reference purposes only," so training should emphasize the actual mandatory requirements in 1910.66, site-specific procedures, manufacturer instructions, and any engineering controls.

Under 1910.66AppB, are employers required to post or keep the Appendix B drawings at the job site?

No — Appendix B does not require employers to post or keep the drawings at the job site. The figures are advisory illustrations in 1910.66AppB. Employers should, however, maintain any required design documents, manufacturer instructions, and records that demonstrate compliance with the mandatory provisions of 1910.66 and their site-specific safety program.

Under 1910.66AppB, can an employer design a custom button guide system (Figure 3) without consulting the platform manufacturer or an engineer?

No — designing a custom button guide system without consulting the manufacturer or an engineer can be unsafe and may not meet mandatory requirements. Appendix B only shows an illustrative button guide in 1910.66AppB. Employers must ensure the custom design meets the performance, structural, and safety requirements in 1910.66 and should obtain competent engineering review or manufacturer approval where appropriate.

Under 1910.66AppB, do OSHA inspectors use the appendix figures as the sole basis for judging whether a stabilization system is compliant?

No — OSHA inspectors do not use Appendix B figures as the sole basis for compliance decisions. Appendix B is advisory and "do not illustrate all the mandatory requirements for each system," so inspectors evaluate actual compliance against the mandatory provisions of 1910.66 and relevant interpretations or guidance.

Under 1910.66AppB, if a stabilization system follows an appendix drawing but lacks required PPE or head protection policies, is the employer still compliant?

No — following an appendix drawing alone does not make an employer compliant if other mandatory safety requirements (like PPE or head protection) are missing. Appendix B is only illustrative; employers must meet all applicable standards such as general PPE requirements in 1910 and, where relevant, the head protection requirement discussed in OSHA's letter on head protection for crane operators at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2 which explains employers must provide protective helmets where there is a risk of head injury.

Under 1910.66AppB, may procurement specifications reference Appendix B figures as an "acceptable example" when soliciting platform stabilization systems?

Yes — procurement documents may reference the Appendix B figures as an "acceptable example," but the solicitation must require that bidders meet all mandatory requirements of 1910.66. Because Appendix B illustrations are advisory, the procurement should also require certified design documentation, engineering calculations, manufacturer specifications, and evidence that the delivered system complies with the governing standard.

Under 1910.66AppB, where can I find the official advisory figures for typical platform stabilization systems?

The advisory figures are published in 1910.66AppB. Appendix B contains three drawings labeled as typical platform stabilization systems and is explicitly advisory—use the figures as visual references only and follow the mandatory text in 1910.66 for legal requirements.