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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.
January 22, 1992
MEMORANDUM FOR: REGIONAL ADMINISTRATORS FROM: PATRICIA K. CLARK, Director Directorate of Compliance Programs SUBJECT: Use of Filler Compounds Such as "Bondo" to Cover and Conceal Structural Damage to Maritime Cargo Handling Gear
It has been brought to our attention that structural damage to cargo handling gear installed on vessels is being concealed by covering over damaged areas with a filler material such as "Bondo." Suspect areas where this condition might exist can be identified by lightly striking the surface with a hammer which causes the filler material to crack and fall out. Currently, we are aware of this recognizable unsafe practice having been identified on the following foreign registry vessels while conducting longshoring operations in U.S. ports on the west coast: M/V SUN PACIFIC (NKK Registry), M/V HELM STAR (NKK Registry), and M/V BLUE COSMOS (NKK Registry). However, compliance officers are to be advised that this practice could occur on any vessel-mounted or shore-based cargo handling gear. Agencies accredited to certificate maritime cargo handling devices have been advised of this unsafe practice by separate correspondence.
Concealing structural damage on cargo handling gear constitutes an extremely serious and unsafe occupational hazard. If you have any additional information or documentation with respect to incidents involving this unsafe practice, please contact [the Division of Maritime Compliance Assistance at (202) 693-2399].