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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 27, 1991

Mr. Michael Hoffer
Vice President of Marketing
866 King Edward Street
Winnipeg, Manitobaz
Canada R3H OP7

Dear Mr. Hoffer:

This is in response to your letter of March 12, in which you inquired as to whether the Occupational Safety and Health Administration (OSHA) had regulations requiring bus maintenance facilities to use safety stands when maintenance personnel are working under buses which have been raised by in-ground portable vehicle hoists. We apologize for the delay in this response.

Regulations do exist addressing servicing and maintenance operations. 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout), applies to general industry employment and covers the servicing and maintenance of machines and equipment in which the unexpected startup or the release of stored energy could cause injury to employees. This standard applies with respect to potential hazard of a falling bus body during maintenance operations. This new rule requires that, in general, before servicing or maintenance is performed on machinery or equipment, the machinery or equipment must be turned off and disconnected from the energy source, and the energy isolating device must be either locked or tagged out. A portable vehicle hoist would not normally be considered by itself to provide effective protection for the hazard of falling buses under the Lockout/Tagout standard. In-ground vehicle hoists may provide sufficient protection depending on their design and utilization. OSHA would expect the employer to follow the recommended practices in any national consensus standard, such as the American National Standards Institute (ANSI) standard B153.1-1990, for Automotive Lifts- Safety Requirements for the Construction, Care, and Use. Additionally, manufacturers recommendations and specifications should be followed. We have enclosed a copy of the lockout/tagout standard for your information and use.

We hope this helps to clarify your concerns. Your interest in workplace safety and health is appreciated.


Patricia K. Clark, Director
Directorate of Compliance Programs