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.

May 11, 1984

Mr. Richard A. Happel, Jr.
Director-Safety Engineering
JLG Industries, Inc.
JLG Drive
McConnellsburg, Pennsylvania 17233-9990

Dear Mr. Happel:

This is in response to your letter of May 3, concerning the application of the Occupational Safety and Health Administration's (OSHA) standards.

OSHA does not issue citations for alleged violations of specific standards beyond the intended scope of the regulations. As you indicated in your correspondence, aerial lifts are not also covered by portions of the crane and derrick standards which could by applied to aerial lifts because of similarities between the two types of equipment.

I hope this information is helpful to you. If we can be of further assistance, please let us know.


John B. Miles, Jr., Director
Directorate of Field Operations