|OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
March 6, 1989
||JAMES W LAKE,
Regional Administrator, Region X
||LEO CAREY, Director
Office of Field Programs
||THOMAS J SHEPICH, Director
Directorate of Compliance Programs
||GERALD P REIDY, Director
Office of Construction and Maritime Compliance Assistance
||Interpretation re: "Billy Pugh" basket
This is in response to your memorandum dated January 18, 1989 regarding the use of the "Billy Pugh" type basket for personnel transfer to and from a boat.
As you are aware, there are no regulations in the OSHA maritime or general industry standards that address transferring personnel from an oil platform to and from a boat.
As far as the Construction Standards are concerned, the "Billy Pugh" basket does not meet the requirements of 29 CFR 1926.550(g)(4), "Crane or Derrick suspended Personnel Platforms." Specifically, the basket does not meet the requirements of sections 1926.550(g)(4)(i)(b), 1926.550(g)(4)(ii)(a), 1926.550(g)(4)(ii)(b), 1926.550(g)(4)(ii)(e), 1926.550(g)(4)(ii)(f), 1926.550(g)(4)(ii)(i) and 1926.550(g)(4)(iv)(a). It is also felt that this basket could not be brought into compliance with this construction standard.
We would suggest that if the basket is used to transfer personnel, that a safety belt be used to provide a more positive means of preventing a person from falling from the basket, particularly in rough weather, and tag lines be attached to the basket to help guide it to its destination.