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.

December 6, 1991

Mr. Richard F. Hoffman
President
McLean Contracting Company
6700 McLean Way
Glen Burnie, Maryland 21060-6480

Dear Mr. Hoffman:

This is in response to your September 26 letter requesting the Occupational Safety and Health Administration (OSHA) to comment on or confirm as acceptable your procedures for determining when the use of crane or derrick suspended personnel platforms is the safest and only means of accessing a worksite. I apologize for the delay in responding to your inquiry.

We have reviewed your procedures for hazard/risk analysis used to determine when it is appropriate to use crane suspended work platforms, your company policy on their use, and the field authorization form. The procedures and documentation outlined in your letter comply with OSHA's requirements for determining the safest access to elevated work sites, provided the person authorizing the use of a crane for personnel hoisting purposes and signing the field authorization form is a competent person as defined in 29 CFR 1926.32(f). Note, however, that it would generally not be appropriate for a competent person to evaluate medical factors such as fatigue and risks of cardiac incidents without the assistance of a physician.

If we can be of any further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8124.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs