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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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



September 27, 1977



Field Coordinator
Deputy Director, Federal Compliance
and State Programs
SUBJECT: Standard Clarification Request of 29 CFR 1910.179(e)(6)(i) and (g)(2)(i)


This is in response to the memorandum to: Office of the Field Coordinator Bill Demery, Acting Director NEP; From: W. Gary Adams, Acting Director, NEPCC; dated July 15, 1977; same subject. Mr. Adams requests an interpretation of the term "normal operating conditions" as used in 29 CFR 1910.179(e)(6)(i) and (g)(2)(i) Overhead and Gantry Cranes.

Specifically, Mr. Adams asks "if the only exposed employees in these cases are maintenance men who do occasional maintenance on the crane bridge foot-walk is this exposure during normal operating conditions ---?".

The answer to this question is in the affirmative. OSHA's position is that "normal operating conditions" include maintenance activity.

This office, in the near future, will issue a program directive defining the term as used in the cranes and derricks standards.