- 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.
May 8, 1989
Mr. Louis Horvath, President
American Climber & Machine Corp.
Post Office Box 471
Lisbon, Ohio 44432
Dear Mr. Horvath:
This is in response to your letter of March 10, 1989, addressed to Mr. Barry White, Director, Directorate of Safety Standards, concerning a "cable grab" device that will not allow the free end of the wire rope to exit the hoist.
As you may be aware, not all recognized hazards are addressed by detailed Occupational Safety and Health Administration (OSHA) standards. OSHA sometimes relies on standards from other sources such as the Underwriters Laboratories, Inc. (UL). Standard UL 1323-1988 SCAFFOLD HOISTS, addresses problems such as: "cable grab" devices that will not allow the free end of the wire rope to exit the hoist.
To make sure we had the most up-to-date information, we contacted UL and discussed "cable grab" devices. They verified that UL 1323-1988 is the latest information and that the "cable grab" devices are addressed in section 42 (Operation Test-Hoist Run Off) which states: "While supporting 100 percent of its rated working load the hoist shall be run at its maximum speed off the end of the support to check that the secondary brake will catch, stop, and hold the loaded hoist for two minutes."
We also contacted Mr. Richard Dayoub's Area Office in Jacksonville, Florida, and inquired as to his position on putting fist grips on the free end of the hoist cables to prevent the hoist from running out. The Area Office agrees that UL 1323-1988 is the document to use for scaffold hoist compliance.
Enclosed, in part, is a copy of the UL Standard for Safety UL 1323-1988, SCAFFOLD HOISTS. For more information regarding procedures for Powered Scaffold Hoists, it is suggested you contact:
Underwriters Laboratories, Inc.
333 Pfingsten Road
Northbrook, IL 60062-2096 USA
Telephone: (847) 272-8800
Fax: (847) 272-8129
If we may be of further assistance, please contact us.
Patricia K. Clark, Acting Director
[Directorate of Enforcement Programs]
March 10, 1989
OSHA Room #3605
Washington, DC 20210
ATTENTION: Mr. Barry White, Director of Safety Standards
SUBJECT: Section 5(a)(1) - OSHA Act of 1970
Dear Mr. White;
As per my telephone conversation this morning with Mr. Richard Dayoub of the OSHA office in Jacksonville, Florida office suggested that I also contact you for further information on this matter.
We are manufacturers of the American Climber Powered Scaffold Hoists. These are traction-type hoists with raise/lower contractors in high-rise applications.
Our equipment is Underwriters Laboratories (UL) classified for this specific application in this industry. UL is stating that according to UL and OSHA that we will have to incorporate a "Cable Grab" device that will not allow the free end of the wire rope to exit the hoist. I have stated to UL that American Climber suggests that to prevent the free end of the wire rope from running through the hoist that by simply putting a fist grip on this free end that the cable cannot run out. This is simple and inexpensive to do. We do not rely on this as our primary brake.
My conversation with Mr. Dayoub confirmed that this is acceptable with OSHA and it is not necessary to incorporate an additional device.
I am writing to you to ask your opinion on this matter. I believe that according to section 5(a)(1) that this fist grip is acceptable and that reasonable care should be taken by the employer to advise the employee on the proper safety needed in this application and any application.
I will be awaiting for your response to this matter and I will also show your response to UL. I thank you for your time and attention in this matter.