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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.
November 5, 1991
MEMORANDUM FOR: R. DAVIS LAYNE REGIONAL ADMINISTRATOR THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS FROM: PATRICIA K. CLARK, DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS SUBJECT: Load Charts for Mobile Cranes
This is in response to your August 14 memorandum in which you request clarification of the load chart posting and visibility requirements for mobile cranes.
We agree with your statement that the crane industry is currently supplying information, including load charts, in a manner different than what was done and acceptable to OSHA in the past. Consequently, it is our interpretation that the posting requirements of 29 CFR 1910.180(c)(2), "...securely fixed...;" 29 CFR 1926.550(a)(2), "...shall be conspicuously posted...;" and 29 CFR 1926.550(f)(1)(ii), "...securely fixed...;" are met when the required information is contained in a notebook securely attached to the interior of the crane cab, such as by the use of a lanyard. However, this interpretation does not change the need to have the relevant instructions, warnings and load rating charts for a lift "visible to the operator" as required by 29 CFR 1910.180(c)(2), 29 CFR 1926.550(a)(2), and 29 CFR 1926.550(f)(1)(ii). When information is contained in bookform, a way of complying with these provisions would be to provide a bookholder designed to keep the book open to the relevant page(s), and located so as to be visible to the operator while at the control station.
With these interpretations, we do not believe an OSHA Instruction STD is necessary.