January 16, 2004
Mr. Larry Birchler
675 Liverpool Drive
P.O. Box 464
Valley City, Ohio 44280
Dear Mr. Birchler:
Thank you for your August 8 letter to the Occupational Safety and Health Administration's (OSHA) Cleveland Area Office. Your letter has been referred to OSHA's Directorate of Enforcement Program's (DEP) Office of General Industry Enforcement for an answer to your question regarding compliance with OSHA's Overhead and Gantry Crane Standard, 29 CFR 1910.179. Specifically, you requested clarification on whether or not your Automation Transfer Device needs to meet the above crane standards. It is my understanding that you have spoken to my staff in regards to this matter and you have sent additional documentation. Your question and scenario have been restated below for clarity.
Scenario: Webb-Stiles is a designer, manufacturer, and installer of custom applied conveying systems. The automatic transfer units act like a conveyor, they take a product from a conveyor, process it, and deliver the product back onto a conveyor, all automatically. The entire transfer machinery and its motions are fully automatic, electrically and mechanically guarded from production and maintenance personnel when in operation. The raising and lowering is accomplished via a guided carriage powered by eight RC 100 chains. The chains are driven by conventional shafting and sprockets connected to an electrical driven gearbox. The product weight handled is a controlled weight serviced by the delivering conveyor. The delivering conveyor has limitations on the product weight that can be handled.
Webb-Stiles installed a machinery automation device in a facility located in Nebraska. Four transfer devices operating as transfer devices in an automatic mode (no people required) to transfer loads from tank to tank in a process that cleans and paints metal. The product to be dipped is delivered by a conveyor to the process area and automatically transferred into the tank automation transfer machines. The product to be handled is loaded at remote stations serviced by the conveyor system that delivers load bars to the transfer machines. The parts are suspended from a load bar; the bar then is transferred via the conveyor to the automation transfer machines. The bar and its conveyance system have design capacity limitations that must be met by the load operator. Load patterns must be issued via controlled manufacturing process data sheets. After the last tank operation, one of the four units transfers the load bar onto other conveyors for additional processing. These transfers use counter weights to help in raising the load. The counter weights are applied in such a way that the worst case horsepower, torque, and brake capacity actually occurs when there is no product load. The lifting chains are applied in such a way that only four of eight chains are sufficient in capacity for the payload and counter weight. The eight chains are grouped into four suspension points of two chains each. Under chain failure, one of these two chains must remain in place to continue to operate the transfer machine in a safe manner, i.e., each suspension point must have at least one chain active to operate safely. For this type of equipment, American National Standards Institute (ANSI) B20.1 Conveyor standards; ANSI B15.1 Power Transmission Standards; ANSI B29.1 Precision Power Transmission Roller Chains, Attachments and Sprockets; AISC standards for steel and fasteners; and AGMA ratings for gears and gearboxes would be applied.
Question: Does OSHA consider the above automation transfer device a crane and therefore required to meet 29 CFR 1910.179?
Reply: OSHA cannot fully make that determination without an on-site inspection of the equipment. However, it does appear from the information provided that the equipment described above would most likely be considered a conveyor rather than a crane. Therefore, OSHA's Overhead and Gantry Crane standard may not apply.
Please be aware that since your equipment is custom designed and manufactured, there may be circumstances where 29 CFR 1910.179 would be applicable. In addition, other OSHA standards, such as but not limited to, Subpart D - Walking and Working Surfaces, Subpart O - Machine Guarding, and Subpart S - Electrical may still apply to your equipment, regardless of whether the crane standards apply. Further, Section 5(a)(1) of the OSH Act requires employers to protect employees from serious recognized hazards. OSHA may cite Section 5(a)(1) of the OSH Act in the absence of an applicable OSHA standard if there are serious recognized hazards with the automation transfer device described above.
As the manufacturer of custom engineered conveyor systems, Webb-Stiles must determine the proper uses, functions, and testing of its custom products. It is recommended that Webb-Stiles contact a Nationally Recognized Testing Laboratory (NRTL) for information on the possible listing and labeling of its products. More information about OSHA's NRTL program can be found at http://www.osha.gov by selecting the letter "N" in the Site Index at the top of the page.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretations letters explain the 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. In addition, 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. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.
Richard E. Fairfax, Director
Directorate of Enforcement Programs