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 30, 1984

Mr. Andrew Cicillini
Chief Elevator Inspector
Department of Labor
Division of Occupational Safety
220 Elmwood Avenue
Providence, Rhode Island 02907

Dear Mr. Cicillini:

This is in response to your letter of July 10, 1984, concerning vertical reciprocating conveyors.

The Occupational Safety and Health Administration (OSHA) regulates the use of vertical reciprocating conveyors used in general industry under various standards relative to specific types of applications. These regulations can be found at 29 CFR 1910.107(b)(7), .107(h)(7), .108(c)(6), .218(j)(3), .263(d)(7), .263(i)(7), and .265(c)(18). All other applications of conveyors are regulated under 29 CFR 1910.212, general requirements for all machines. In this regard, OSHA relies on the recommendations of the ANSI B20.1-1976 for the acceptable safeguarding of employees exposed to conveyors.

ANSI B20.1-1976, sections 5.12.4 and prohibit the riding of vertical and vertical reciprocating conveyors. As a result of these recommendations, OSHA does not permit the riding of such conveyors by personnel. Therefore, since these conveyors are not intended for the transport of personnel, they are not properly within the scope or application of the elevator standards set forth by ANSI A17.1.

OSHA considers the riding of vertical reciprocating conveyors by employees to be in violation of 29 CFR 1910.212(a)(1) in that, the safety of personnel cannot be assured. However, should such an installation also meet the criteria of ANSI A17.1, OSHA would reevaluate this position relative to such specific installations.

I hope this information is useful to you and your panel. If we may be of further assistance, please contact us.


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

July 10, 1984

Mr. J. J. Kocko, Jr.
US Dept. of Labor
Washington, D.C.


As Chief Elevator Inspector for the State of Rhode Island, I have served as a member of our Elevator Advisory Panel for some time. This panel was set up in order to review and revise elevator safety codes and standards, and to discuss any new materials relative to the elevator industry. It's main purpose is to insure safety for all types of vertical transportation.

During our last meeting, the panel raised several questions concerning vertical reciprocating conveyors, equipped with a ridable platform. It would seem that the National Association of Elevator Safety Authorities, the B-20 Committee, does not agree with our interpretation of these installations. The B-20 committee feels that these types of units do not fall under the classification of an elevator and therefore are not subject to the elevator code.

It is our feeling that the vertical reciprocating conveyor, equipped with a ridable platform, moving in fixed guides, and serving two or more stories is an elevator and should be subject to the elevator codes.

We are very interested in obtaining information from other States relative to this type of installation, and would like to request your enforcement agency forward said information, if available, to our office. Any information which can be supplied to us would be greatly appreciated, and very helpful to our panels discussion of these units.

Please forward your replies to my attention at the above address.

Yours truly,

Andrew Cicillini
Chief Elevator Inspector