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.

July 17 1975

Mr. Robert E. Schumacher
General Manager
High Plains Insurance, Inc.
P.O. Box 100
Hays, Kansas 67601

Dear Mr. Schumacher:

This is in response to your letter of May 21, 1975, regarding aerial ladders or booms.

Enclosed is a copy of 29 CFR 1910.67, Vehicle-Mounted Elevating and Rotating Work Platforms amendment, that was published in the Federal Register of March 6, 1975. This amendment gives you the answer to your questions.

There is nothing in the wording of 1910.67 that requires the employer to certify and designate an operator to another party. Employers have the responsibility of devising methods to train their operators in the safe operation of aerial lifts. Only competent and careful operators should be assigned these duties. The operator shall be trained in safe operations and made familiar with the manufacturer's manual, especially those parts which relate to operation, maintenance, and safety of aerial devices.

If I can be of any further assistance, please feel free to contact me.


Janet H. Sprickman
Acting Chief
Division of Occupational
Safety Programming