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.

March 16, 1987

SUBJECT: Standards Interpretation Regarding Applicability of 29 CFR
  1910.180(b)(1) to Cranes Used with Drag Line, Pile
  driver or Clam Shell Attachments.

Reference is made to your memorandum dated February 24, 1987, on the above subject.

Commissioner Fornaro's letter requests a clarification of the applicability of the general industry standard, 29 CFR 1910.180(b)(1), to cranes used in drag line, pile driving, and/or clam shell operations. The general industry standard, 29 CFR 1910, is inapplicable to pile driving operations because under the definition of 29 CFR 1910.12(b) and the scope of 29 CFR 1926, Subpart 0, pile driving would only occur during construction or marine operations. Therefore, 29 CFR 1926, Subpart 0, is applicable to pile driving operations including those which utilize a crawler, locomotive, or truck crane.

Hazardous operations involving crawler, locomotive, and truck cranes used with drag line or clam shell attachments in general industry settings shall be cited as general duty clause, 5(a)(1) violations. Such 5(a)(1) violations should reference the applicable Power Crane and Shovel Association Standards No. 1 and No. 2 of 1968, or No. 3 of 1969. The construction standards may also be referenced.