Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

December 22, 1976

Mr. I. Dean Riley, President
Ladder Towers, Incorporated
Commerical Division-Export Division
51 Industrial Circle
Conestoga Valley Industrial Center
Lancaster, Pennsylvania 17601

Dear Mr Riley:

This is in response to your correspondence of November 22, 1976, regarding man-lift standards and interpretations.

Your term "man-lift" could mean any device or equipment used to lift man. The Occupational Safety and Health Administration (OSHA) has numerous standards covering equipment or devices used to lift man. In addition, OSHA has adopted serveral different American National Standards Institute (ANSI) standards for OSHA standards, including the following: (ANSI) A92.2-1969; ANSI A10.4-1963; ANSI A17.1-1965; ANSI A120.1-1970; and ANSI B30.5-1968.

As noted in OSHA Programs Directive (PD) #100-48, OSHA standards, other than 29 CFR 1910.180(h)(3)(v) and 29 CFR 1926.550(b)(2), permit the use of crane-suspended working platforms. Second, in our judgment, the use of crane-suspended working platforms under controlled conditions offers the safest means of completing difficult work assignments in certain cases. OSHA PD#100-48 (Revision #1) has been developed to clarify the term "controlled conditions." While we recognize that crane-suspended working platforms are not danger free, we feel that, in some cases, alternative construction methods are comparatively more hazardous. Third, our interpretation is consistent with the ANSI B30 Committee's interpretation of the cited language, which permits the use of crane-suspended working platforms. In some cases, the crane manufacturers have made available work platforms for purchase and use with their cranes. It also has been acknowledged by manufacturers that the use of suspended working platforms are "relatively common within the industry." The main requisite is that the safety of the employees working on a suspended platform is reasonably assured.

If your vehicle mounted fire fighting equipment was in the scope of 29 CFR 1910.67 Vehicle-Mounted Elevating and Rotating Work Platforms, your equipment would be defined as an aerial ladder with platform and be required to meet this general industry standard.

In the Construction Safety and Health Regulations, Part 1926, your aerial device would be required to meet the requirements of 29 CFR 1926.556, Aerial Lifts. Where there are no specific OSHA standards applicable to the particular hazard, the employer is required to comply with Section 5(a)(1) of the Occupational Safety and Health Act of 1970, which states: Each employer shall furnish to each of his employees employment and a place of employement which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

Thank you for your continuing interest in safety and health.


Bert M. Concklin
Deputy Assistant Secretary