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.

August 10, 1983

Mr. Michael I. Fanning
Safety and Health Services
The Associated General Contractors
of America
1957 E Street, N.W.
Washington, D.C. 20006

Dear Mr. Fanning:

This is in response to your letter of July 27, 1983, concerning the use of cranes with work platforms connected (not suspended) from the last section of the crane boom.

Cranes used routinely in construction and general industry to lift personnel or material must meet the applicable design and safety requirements of 29 CFR 1926.556 or 29 CFR 1910.67 for personnel carriers. In other words, the crane boom and attached platform as a combination must be primarily designed as a personnel carrier if they are to be routinely used in this manner. Therefore, as required by the above-mentioned standards, the crane must have both platform (upper) and lower controls when personnel platforms are occasionally attached for routine work situations.

OSHA Instruction STD-1-11.2B allows cranes to be used to hoist and suspend personnel on a work platform, or to provide access in unique work situations, only when such action results in the least hazardous exposures to employees. An acceptable example would be a crane suspending a work platform with an employee used to examine a damaged highrise building for structural defects in an emergency situation. When used in this manner, the crane with attached work platform is not primarily designed as a personnel carrier and therefore does not require upper controls for the employees in the work platform. The operation and equipment must be in compliance with the guidelines in the OSHA Instruction.

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

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


Bruce Hillenbrand
Director, Federal Compliance
and State Programs