September 27, 1977
||DONALD E. MACKENZIE|
||RICHARD P. WILSON|
Deputy Director, Federal Compliance
and State Programs
||Standard Clarification Request of 29 CFR 1910.179(e)(6)(i) and (g)(2)(i)|
This is in response to the memorandum to: Office of the Field Coordinator
Bill Demery, Acting Director NEP; From: W. Gary Adams, Acting Director,
NEPCC; dated July 15, 1977; same subject. Mr. Adams requests an
interpretation of the term "normal operating conditions" as used in
29 CFR 1910.179(e)(6)(i) and (g)(2)(i) Overhead and Gantry Cranes.
Specifically, Mr. Adams asks "if the only exposed employees in these
cases are maintenance men who do occasional maintenance on the crane
bridge foot-walk is this exposure during normal operating
The answer to this question is in the affirmative. OSHA's position is
that "normal operating conditions" include maintenance activity.
This office, in the near future, will issue a program directive
defining the term as used in the cranes and derricks standards.