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June 8, 1998
Jerry M. Gillooly
Safety Manager
Bohl Crane, Inc.
534 Laskey Road
Toledo, Ohio 43612
Dear Mr. Gillooly:
This is in response to your March 3 letter addressed to Mr. Roy Gurnham, Occupational Safety
and Health Administration (OSHA) seeking an interpretation of 29 CFR §1926.502(d)(23) and
guidance in identifying acceptable methods for accessing a crane runway from an aerial lift.
The referenced regulation prohibits personal fall arrest systems from being attached to guardrail
systems or to hoists except as specified in other subparts of this part. This would apply to all
guardrail excepting those that have been specifically designed for such use in accordance with the
requirements of §1926.502(d)(15).
In the situation you described where suitable anchorage points are not provided for on cranes,
employers are to be guided by §1926.502(a)(2), which instructs them to provide and install all
fall protection systems for employees and comply with other pertinent subpart requirements
before the employee begins work that necessitates the fall protection. Simply put, in situations
where the status of appropriate anchorages are unknown or suspected to be inadequate,
employers should discuss safe ways to access crane runways and other areas where work is to be
conducted. Such planning should anticipate where proper anchorages are to be located prior to
work being started instead of using alternative anchorage points which may not comply with this
subpart.
If you require any further assistance, please do not hesitate to contact us again by writing to:
Directorate of Construction - OSHA, Office of Construction Standards and Compliance
Assistance, Room N3621, 200 Constitution Avenue, N.W., Washington, D.C. 20210
Sincerely,
Russell B. Swanson, Director
Directorate of Construction
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Standard Interpretations - Table of Contents
