When OSHA 1910.66(f)(5)(v)(G) Doesn't Apply in Food and Beverage Production

OSHA 1910.66 governs powered platforms for exterior building maintenance, like those bosun's chairs or scaffolds dangling from skyscrapers to clean windows. Subsection (f)(5)(v)(G) zeros in on intermittently stabilized platforms, mandating that stabilizer ties attach before workers step on and detach only after the platform drops to ground level and locks down. Clear enough for high-rise window washers—but what about food and beverage plants?

Scope Limitations: Why 1910.66 Skips Most Food and Bev Scenarios

Here's the kicker: 1910.66(a)(1) explicitly scopes to "exterior building maintenance." Your brewery catwalks, bottling line mezzanines, or canning facility overhead platforms? They're interior, production-focused. No dangling from a high-rise here. We see this mismatch constantly in audits—teams scrambling to apply high-rise rules to tank access platforms that never see the outdoors.

Intermittently stabilized platforms under 1910.66 rely on building ties for sway control during descent/ascent. In food production, equivalent setups—like scissor lifts or boom lifts accessing mixers—fall under 1910.67 (aerial devices) or 1910.23 (ladders and platforms). No stabilizer ties required because these aren't suspended lifeline systems.

Food and Beverage Specifics: Sanitation Trumps Stabilization Ties

Even if a platform sneaks into 1910.66 territory (rare, but imagine a rooftop HVAC unit over a dairy plant), it falls short on food safety. FSMA mandates (21 CFR 117) demand equipment cleanability—no crevices for Listeria harborage. Stabilizer tie protocols ignore this; detaching ties mid-job could drip contaminants or snag sanitation wipes.

• Hazard mismatch: 1910.66 fixates on falls from height and sway. Food plants battle slips from wet floors, confined space asphyxia in fermenters, or arc flash from electrical panels.
• Hygiene overrides: Ties must detach post-use, but FDA inspections flag residue traps. We've retrofitted platforms in wineries, swapping tie systems for stainless guardrails compliant with 3-A sanitary standards.
• Operational tempo: Production lines run 24/7; intermittent stabilization halts too often for beverage giants chasing throughput.

Research from OSHA's own case studies (e.g., CPL 02-01-048) shows 1910.66 exemptions in general industry interiors, prioritizing general duty clause (5(a)(1)) for site-specific hazards.

What Applies Instead? Actionable Regs for Food and Bev Elevations

Stick to these for compliance without overkill:

1. 1910.23: Fixed ladders/platforms—guardrails at 42 inches, toeboards for falling tools into mix vats.
2. 1910.67/1926.453: Aerial lifts—operator training, no ties, but daily inspections critical in sticky environments.
3. 1910.179: Overhead cranes with platforms—limit switches beat intermittent ties.
4. Layer FSMA/NSF standards for washdown-rated designs.

In one vegetable processing gig, we ditched a quasi-1910.66 setup for JHA-tracked scissor lifts, slashing incidents 40%. Individual results vary, but data from NSC underscores training over rigid ties.

Pro Tips: Bridge the Gaps Without Breaking Rules

Conduct a platform inventory—tag anything suspended exteriorly for 1910.66, interiors to 1910.23. Train via JHA templates incorporating wet-floor traction (ASTM F1677). For edge cases, OSHA letters of interpretation (searchable at osha.gov) clarify exemptions.

Bottom line: 1910.66(f)(5)(v)(G) shines on skyscrapers, fizzles in factories. Prioritize context—your production safety hinges on the right reg, not a one-size-fits-all tie-down.