- 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 11, 1989
Mr. John M. Hamment Shawe and Rosenthal Sun Life Building Charles Center Baltimore, Maryland 21201
Dear Mr. Hamment:
This is in response to your letter and subsequent telephone conversations with Mr. Anthony Brown of my staff concerning the application of the new construction standard for cranes and derricks to your client, McLean Construction Company.
We have reviewed the issues raised in your request for interpretation of 29 CFR 1926.550(g) and the information obtained during the site visit to a harbor project operated by McLean Construction Company, and reaffirm that the barge mounted cranes/derricks are not exempt from this standard.
Your concerns and questions about the standard (1926.550(q)), are centered on the assumption that barge based cranes are not covered by the standard and cannot be retrofitted because of the uniqueness of the work being done. The following comments should help clear up the questions of applicability and provide a basis for compliance with the standards.
1. Controlled load lowering--Backing the load line down through the gear train is not controlled load lowering because:
a. backing the line down does not stop descent, and
b. backing the line is a procedure, not a system or device on the power train.
2. One Degree Level--The barge may list as much as 5 degrees under ANSI B30.8-1982 Section 8-1.2.2(3). The crane mounted on the barge must be level within l degree and the employer must ensure that the cranes capacity is derated to account for the barges deviation from level.
3. Live Boom--the mechanical set up in use (dog system) is no problem, but the company must ensure that no personnel are being hoisted when the boom angle is changed.
4. Anti-Two-Blocking Devices--The requirements for a positive acting system is necessary because no other approach provides equivalent protection. The Agency has recognized the difficulty that some crane uses/owners have had in acquiring the appropriate-equipment for compliance with the standard and is preparing interim relief from the standard. See attachment.
The Occupational Safety and Health Administration (OSHA) advises employers to take a hard look at their operations and alternatives before they decide that hoisting of personnel by crane is appropriate or really necessary.
Please contact this office if you have any further questions about any of these issues covered above.
Gerald P. Reidy, Director Office of Construction and Maritime Compliance Assistance