Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

May 23, 1989

Karl Brendal, P.E.
National Cooperative Refinery Association
200 South Main Street
Post Office Box 1404
McPherson, Kansas 67460

Dear Mr. Brendal

This is in response to your correspondence and subsequent phone conversations with members of my staff, concerning which standard(s) would apply to a personnel platform attached directly to a boom.

Your statement concerning the applicability of [29 CFR 1926.550(g)] and [1926.453] is correct; primarily because adding a work platform attached directly to the end of a boom changes the use of the crane to a personnel carrier. Therefore, all requirements of aerial lifts would apply. Also this change would be a modification after the effective date of the standard and the unit would be required to meet the applicable requirements of the American National Standards Institute for "Vehicle Mounted Elevating and Rotating Work Platforms," ANSI A92.2-1969. You are also correct in requiring for dual controls which are addressed in [29 CFR 1926.453].

We appreciate your interest in safety and health matters and in promoting the safe application of hoisting equipment. We also appreciate your desire to comply with all applicable standards. If we can provide additional information, feel free to contact our office.


Gerald P. Reidy, Director
[Directorate of Construction]

[Corrected 6/2/2005]