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.

March 8, 1990

Mr. F. E. Brady
Manager of Engineering
Gaffey Incorporated
6951 East 12th Street
Tulsa, Oklahoma 74112-5687

Dear Mr. Brady:

This is in response to your letter of January 10, to Mr. Hinkle of our Oklahoma City office concerning an engine overhaul work station being developed by your company. Your letter was forwarded for our response.

The situation of employees working beneath a crane or hoist suspended load is prohibited under the Occupational Safety and Health Act (the Act). However, when a crane hoisting system is augmented with a secondary (redundant) support system which can reliably support the load, the safety of workers can be assured.

The device and arrangement of your engine overhaul work station would be an acceptable configuration and would provide for compliance with the Act. This interpretation assumes that the user would properly maintain the equipment and apply it within the limitations imposed by the manufacturer.

Should you desire an interpretation from the ANSI B30.11 committee regarding their standard, we recommend that you contact then directly.

If we may be of further assistance, please contact us.

Sincerely,

Patricia K. Clark, Director Designate
[Directorate of Enforcement Programs]

[Corrected 10/22/2004]