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.

April 23, 1979

Mr. H. W. Beamer
Project Engineer
Pollock Research and Design,
Incorporated
P.O. Box 66
Canfield, Ohio 44406

Dear Mr. Beamer:

This is in response to your recent letter requesting an opinion on the design of trolley bumpers for electric overhead traveling cranes.

Your idea of a combination bumper and final stop to be mounted on all four corners of the bridge for old cranes that have cast iron trolley frames appears to comply with the intent of the Overload Gantry Crane Standards, provided that:

The bumpers shall be capable of stopping the trolley (not including the lifted load) at an average rate of deceleration not to exceed 4.7 feet/s/s when traveling in either direction at one third of the rated load speed, as required by 29 CFR 1910.179(e)(3)(i).

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

Sincerely,



Grover C. Wrenn Director,
Federal Compliance and State Programs