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.

July 1, 1982

Keith C. Hatsell, P.E.
Director of Engineering
Shepard Niles Crane & Hoist Corporation
Montour Falls, New York 14865

Dear Mr. Hatsell:

This is in response to your letter of June 9, 1982, requesting an interpretation of 29 CFR 1910.179(l)(2)(c). Your letter addressed to Mr. Chester C. Whiteside was forwarded to this office for our interpretation.

It is OSHA's position that the main or emergency switches mentioned in 29 CFR 1910.179(l)(2)(c) must be capable of being locked out. The subject standard does not require two different switches. However, the switches are defined below for your information:

29 CFR 1910.179(a)(59) defines "emergency stop switch" as a manually or automatically operated electric switch to cut off electric power independently of the regular operating controls.

29 CFR 1910.179(a)(61) defines "main switch" as a switch controlling the entire power supply to the crane.

We concur with your interpretations that the pendant push button unit which operates the crane bridge motions does not fall into the category of a main or emergency switch; and the pendant push button units which operate the crane motions do not, currently, include a switch that can be locked out in the open position as a standard feature.

If we may be of further assistance, please contact us.


Patrick R. Tyson
Federal Compliance and State Programs