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.

October 31, 1975

Area Director
SUBJECT: 29 CFR 1910.68(d)(1), Manlifts; Carrying of Lunchboxes on
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This is in response to your memorandum dated September 4, 1975, concerning the subject matter. It also confirms the telephone conversation on October 15, 1975, when you requested a written response.

The intent of this standard, prohibiting transporting of freight, packaged goods, pipe, lumber, or construction materials of any kind on manlifts was to restrict their use by personnel only. Although lunchboxes are not specifically mentioned in the standard, carrying them on a manlift would present the same hazard and in a broad interpretation could be considered as freight or packaged goods. Two reasons for restricting carrying toolboxes on a manlift would be: (1) if the box was dropped or caught between the lift and landing, it may drop on a person below and, (2) one hand must be free to operate the pull stop rope in case of emergency. The same restrictions could apply to lunchboxes. Carrying of tools or other items that protrude from the pockets is also prohibited which would include tool belts and items such as toolboxes (or lunchboxes) on a belt.

John K. Barto, Chief
Division of Occupational Safety Programming