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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

January 16, 1991

Lee Hand Quad City
Testing Laboratory, Inc.
North Brady Street
Industrial Park
17095 214th Street
Davenport, Iowa 52804

Dear Lee:

This correspondence is in response to your letter dated August 30, 1990, and confirms your conversation with Mr. Steve Butler of my staff on January 16, 1991. Please excuse our delay in providing written response.

You have requested clarification concerning the applicable standards which apply on barge loading equipment. As detailed by you the equipment in question is used for unloading coal from barges at a power plant on the Mississippi River, is operated by employees of the power company, and consists of a bulk cargo sucker supported by three cranes.

This barge loading equipment would be covered by maritime standards for the longshoring industry, 29 CFR 1918. Further, this equipment would have to meet the requirements of 1918.13 "Certification of shore-based material handling devices", paragraph (d).

Our current address remains:

         Department of Labor - OSHA
         Office of Construction and
         Maritime Compliance Assistance
         200 Constitution Avenue, N.W. Room N3610
         Washington, D.C.  20210
         Attn:  Gerald P. Reidy

Feel free to write us at the above address or contact us by phone at (202) 523-8131, should you require further clarification or have additional questions.


Gerald P. Reidy, Director
Office of Construction
and Maritime Compliance Assistance