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 https://www.osha.gov.

August 27, 1975

Mr. Don F. Hamilton
House, Holmes & Jewell
1550 Tower Building
Little Rock, Arkansas 7220l

Representing: Arkansas Power & Light Co.

Dear Mr. Hamilton:

This is in response to your letter dated August 14, 1975, concerning your request for variance for the Arkansas Power and Light Company. The standard from which a variance is sought is Section 1910.179(b)(2) Overhead and Gantry Cranes - General Requirements, of the Occupational Safety and Health Standards.

The requirements of the above standard are in part that Overhead and Gantry Cranes shall meet the design specifications of the American National Standard Safety Code for Overhead and Gantry Cranes, ANSI B30.2.0 1967. Section 2-3.2.1 Size of Load states "The crane shall not be loaded beyond its rated load except for test purposes as provided in Section 2-2.2". It is from this requirement that a variance is sought.

You have stated that your overhead crane, which has a rated load of 150 tons, is to be used to lift the reactor vessel head twice per year. The approximate weight of the head is 165 tons. You further state that the crane was built to the specifications certified by the manufacturer's guarantee to be suitable for lifting at 20 percent greater than design rating ton load (180 tons) at least twice a year without causing damage. In addition, you have performed and documented tests beyond the rated load.

The standard requires that the employer shall comply with the manufacturer's specifications and limitations applicable to the operation of any and all cranes. It appears that you are meeting the intent of this standard based on the manufacturer's certification and your own tests. We would suggest that if the testing was accomplished in accordance with the requirements contained in Section 1910.179(k) concerning the testing and thorough check by a qualified engineer or the equipment manufacturer, you should determine if a new rated load may be applicable. If applicable, the new rated load should be displayed as required and records should be maintained and readily available.

Since it appears that a variance from this occupational safety and health standard is not required, no further action will be taken on your application. However, those requirements that may be required by local, State, or other Federal agencies would not be negated.


Barry J. White
Associate Assistant Secretary
for Regional