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June 21, 1984
MEMORANDUM FOR: GILBERT J. SAULTER, Regional Administrator
Region VI
FROM: JOHN B. MILES, JR., Director
Directorate of Field Operations
SUBJECT: Interpretation/Clarification of 29 CFR 1926.605(a)(1)
This will confirm the interpretation of 29 CFR 1926.605(a)(1) requested in
your memorandum dated June 1, and telephoned to Mr. Lyndell Hughes of your
staff on June 8.
STD 3-13.2 states "Construction employers engaged in marine construction
operations are subject aid the construction standards. Cranes and lifting
devices used to move construction materials from shore to barge or form barge
to construction site are not required to be certificated." 29 CFR
1926.605(a)(1) applies to "material handling" operations in "longshoring
operations" as defined in 1926.605(a)(1). Therefore a barge at the
construction site where materials are moved from the barge to the breakwater
construction site, is considered part of the construction process and the
requirement for crane certification does not apply. |