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.

December 30, 1982

Mr. R. B. Jenkins, Engineering Manager
Broderson Manufacturing Corporation
P.O. Box 14770
Lenexa, Kansas 66215

Dear Mr. Jenkins:

This is in response to your letter of December 3, 1982, concerning the use of pin connected work platforms on your rough terrain cranes.

OSHA Instruction STD 1-11.2A allows cranes to be used to hoist and suspend personnel on a work platform or to provide access in unique work situations when such action results in the least hazardous exposure to employees. Broderson cranes are not primarily designed as personnel carriers but may be used in conformance with the above mentioned instruction without upper controls for the employees in the work platform.

Cranes meeting the design and safety requirements of 29 CFR 1926.556 for Aerial Lifts must also have both platform (upper) and lower controls when personnel platforms are occasionally attached for routine work situations. Work platforms complying with 29 CFR 1926.556 or equivalent personnel platforms shall normally be used by employers to elevate personnel to jobsites above ground.

Employers using cranes designed for material handling to hoist or suspend personnel on a work platform in routine situations where the use of other personnel handling equipment can be utilized will be cited for an alleged violation of the standards.

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


Patrick R. Tyson
Director, Federal Compliance
and State Programs