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.

MAR 4 1991

Mr. Thomas W. Hagerty
Mark Crane Service, Inc.
8500 Clinton Road
Cleveland, Ohio 44144

Dear Mr. Hagerty:

This is in response to your letter of January 14, in which you requested clarification of Occupational Safety and Health Administration (OSHA) standard on Overhead and Gantry Cranes, 29 CFR 1910.179.

Your specific questions and our responses are listed below for each of the related sections of the standard, 1910.179:

(b)(1) Does this standard apply to underhung cranes, hoists, and monorails? This standard does not apply to underhung cranes, overhead hoists, or monorails. Underhung cranes and monorails are covered in ANSI B30.11-1980, a National Consensus Standard. Under 1910.179 a hoist is defined as an apparatus which may be a part of an applicable crane, exerting a force for lifting or lowering. Requirements for hoisting equipment can be found in 1910.179(h)(1).

(b)(2) Does existing equipment constructed and installed prior to August 31, 1971 apply to the specification? In addition, do cranes constructed prior to this date and later modernized need to comply? Existing equipment constructed and installed prior to August 31, 1971 is not required to meet this specification. Cranes constructed prior to this date and later modernized are also exempted from this specification; however, such cranes must meet the requirements of 1910.179 (b)(3), Modifications.

(c)(3) Are fire extinguisher required in cabs? Fire extinguisher are not specifically required in cabs, and carbon tetrachloride extinguisher are prohibited. If a fire extinguisher is provided, the employer shall ensure that operators are familiar with the operation and care of the extinguisher.

(d)(2)(iv) Are any clearances required on the footwalks to machinery, electrical controls, etc.? 1910.179 (d)(1)(ii) states: "Where footwalks are located in no case shall less than 48 inches of headroom be provided. Additional requirements for the construction of footwalks can be found in 1910.179 (d)(2)(i), (ii) and (iv).

(g)(1)(iii) Does 240 volts a.c. satisfy the 150 volts a.c. maximum requirement in pendant pushbuttons if the 240 volts a.c., when in a single phase condition at the pendant, is less than this requirement? This section calls for the voltage at the pendant pushbuttons not to exceed 150 volts for a.c. and 300 volts for d.c. If the voltage can be safely reduced so as never to exceed the maximum allowable voltage, then it would be considered acceptable.

(k)(2) Are rated load tests required for new and altered cranes? Yes, rated load tests are required for new and altered cranes.

We hope this helps to clarify these requirements for you. If we may be of further assistance, please do not hesitate to contact us.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs




January 14, 1991

U.S. Department of Labor
Frances Perkins Building
OSHA Room N 3119
200 Constitution Avenue N.W.
Washington, D.C. 20210

Attn: Mr. John Finch

Gentlemen,

We request clarifications on certain sections of the current OSHA criteria dealing with Overhead and Gantry Cranes (1910.179). Please review the following and advise on the respective clarifications:

- Section b.1

Does this standard apply to underhung cranes, hoists, and monorails.

- Section b.2

Does existing equipment constructed and installed prior to August 31, 1971 apply to the specification. In addition, do cranes constructed prior to this date and later modernized need to comply.

- Section C.3

Are fire extinguisher required in cabs.

- Section d.2.IV.

Are any clearances required on the footwalks to machinery, electrical controls, etc.

- Section g.1.iii.

Does 240 volts A.C. satisfy the 150 volts A.C. maximum requirement in pendant pushbuttons if the 240 volts A.C., when in a single phase condition at the pendant, is less than this requirement.

- Section K.2.

Are rated load tests required for new and altered cranes.

Your clarifications of these sections will further enable us in our interpretations of the OSHA requirements.

We thank you in advance for your assistance on this matter.

Sincerely,



Thomas W. Hagerty
Mark Crane Service, Inc.