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.

January 4, 1977

Mr. John Lee Ames, President
United States Crane
Certification Bureau, Inc.
6990 Lake Ellenor Drive
Orlando, Florida 32809

Dear Mr. Ames:

This is in response to your letter of November 22, 1976, addressed to Mr. Klocko, regarding two standards in 29 CFR 1910.179, Overhead and Gantry Cranes. In addition, it confirms a telephone conversation with a member of my staff.

The question you asked, is:

Specifically, on regulations 29 CFR 1910.179(e)(2) Bridge Bumpers, and 29 CFR 1910.179(e)(3) Trolley Bumpers, our question is does the use of travel limit switches in lieu of shock absorbing bumpers meet the requirements to this standard.

The Occupational Safety and Health Administration (OSHA) considers the use of travel limit switches in lieu of bumpers meets the requirements of 29 CFR 1910.179(e)(2) and (e)(3), as long as the limit switches prevent the bridge(s) or Trolley(s) from striking another object. Another object may include another bridge or trolley.

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

Sincerely,



John K. Barto, Chief
Division of Occupational Safety Programming