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December 6, 1991

MEMORANDUM FOR:     MICHAEL G. CONNERS, Director
                    Regional Administrator

THROUGH:            LEO CAREY, Director
                    Office of Field Programs

FROM:               PATRICIA K. CLARK, Director
                    Directorate of Compliance Programs

SUBJECT:            Christmas Treeing Request

This is in response to your July 29 memorandum addressing the SOFCO Erectors, Inc. request for approval of their modified approach to lifting several steel beams at one time. I apologize for the delay in our response.

As noted in your memorandum, although there is considerable agreement in the crane industry that the practice of tandem lifting should be prohibited, there are no OSHA provisions that specifically prohibit multiple-piece steel lifts. In the case you mentioned, the attempt to use 5(a)(1) was unsuccessful because the Structural Manual for Ironworkers, Manual V-Volume 1 was introduced as evidence, and that document states tandem loads, through hazardous, are acceptable as long as "adequate safety precautions" are taken to protect employees. It can be expected this manual would defeat other attempts to cite 5(a)(1) as well. Consequently, your intention to enforce 1926.550(a)(1) and require the employer to "comply with the manufacturer's specifications and limitations applicable to the operation of any and all cranes and derricks," appears to be the best way to proceed at this time. Accordingly, we suggest you include, in paragraph 1 of the draft SOFCO letter, a statement that "Because OSHA considers this practice to be hazardous, prior to any tandem lifting, you must be able to demonstrate that the practice complies with the crane manufacturer's specifications and limitations for the operation of the crane to be used. This may be done by obtaining written concurrence...." However, there is the possibility the manufacturer has no such limitations. Therefore, we suggest you regroup, renumber, and preface paragraphs 4,5,6,7,9, and 10 with a statement such as "In those instances where there are no crane manufacturer specifications, limitations, or statements that prohibit tandem lifting, then the following shall apply:..."

In addition, we suggest that paragraphs 2,3,8 and 11 be grouped together as they are existing OSHA regulations that apply to all lift operations whether tandem or not.

With respect to paragraph 2, please be advised that 29 CFR 1926.251(c)(1) requires a safety factor of only 5.

With respect to paragraph 11, please be advised that although the provisions of 29 CFR 1910.184(c)(9) are not currently listed in the Index of General Industry Standards Applicable to construction, the paragraph is deemed to be applicable to construction activities.

[This document was edited on 1/12/2000, per Federal Register #:63:33450-33469, June 18, 1998, and no longer reflects OSHA's policy for this issue.]

If we may be of further assistance, please call Mr. Roy F. Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at FTS 523-8136.