- Standard Number:
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.
November 29, 1988
Mr. Norman Hargreaves
Reliability and Safety Manager
Koehring Cranes & Excavators, Inc.
Post Office Box 4294
Chatanooga, Tennessee 37405
Dear Mr. Hargreaves:
This is in response to your letter of October 7, concerning 29 CFR 1926.550(g)(3)(i)(G) in the Crane or Derrick Suspended Personnel Platform; Final Rule.
29 CFR 1926.550(g)(3)(i)(G) prohibits the use of machines having live booms (booms in which lowering is controlled by a brake without aid from other devices which slow the lowering speeds). The regulation is clear in its prohibition of any machines using only brakes to lower the crane boom. Your reference to 29 CFR 1926.550(g)(3)(i)(G) is not consistent with your discussion of "controlled load lowering" and automatic brakes which are addressed in 29 CFR 1926.550(g)(3)(i)(D) which stated that a system or device on the power train, other than the load hoist brake must be in place to regulate the lowering rate of speeds of the hoist mechanism (controlled load lowering). Free fall is prohibited.
The Occupational safety and health Administration (OSHA) believes that it is not necessary to promulgate a separate automatic brake requirement on its determination that the brake mechanism of an anti-two-blocking device and controlled load lowering will provide reliable protection for hoisting personnel as stated in the Crane or Derrick suspended Personnel Platforms; Final Rule, page 29123, inserted.
The standard, 29 CFR 1926.550 must be used in its entirety and should not be used in part to lessen the impact of a safety requirement.
If we can be of further service, please contact us.
Thomas J. Shepich, Director
Directorate of Compliance Programs