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November 5, 1991
MEMORANDUM FOR: R. DAVIS LAYNE
REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Load Charts for Mobile Cranes
This is in response to your August 14 memorandum in which you request
clarification of the load chart posting and visibility requirements for
mobile cranes.
We agree with your statement that the crane industry is currently supplying
information, including load charts, in a manner different than what was done
and acceptable to OSHA in the past. Consequently, it is our interpretation
that the posting requirements of 29 CFR 1910.180(c)(2), "...securely
fixed...;" 29 CFR 1926.550(a)(2), "...shall be conspicuously posted...;" and
29 CFR 1926.550(f)(1)(ii), "...securely fixed...;" are met when the required
information is contained in a notebook securely attached to the interior of
the crane cab, such as by the use of a lanyard. However, this interpretation
does not change the need to have the relevant instructions, warnings and load
rating charts for a lift "visible to the operator" as required by 29 CFR
1910.180(c)(2), 29 CFR 1926.550(a)(2), and 29 CFR 1926.550(f)(1)(ii). When
information is contained in bookform, a way of complying with these
provisions would be to provide a bookholder designed to keep the book open to
the relevant page(s), and located so as to be visible to the operator while
at the control station.
With these interpretations, we do not believe an OSHA Instruction STD is
necessary.
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