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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.
February 12, 1992
MEMORANDUM FOR: JAMES W. LAKE REGIONAL ADMINISTRATOR FROM: PATRICIA K. CLARK, DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS Subject: Interpretation of 29 CFR 1910.179(j)(2) with Respect to Inspection of Crane Hooks
This is in response to your memorandum of September 10, 1991 regarding the inspection of crane hooks, in which you reference a response you received from ASME concerning the intent of Paragraph 2-2.1.2(a)(4) of ANSI B30.2.0-1967, which is similar to 29 CFR 1910.179(j)(2)(iii). Based on ASME comments, you recommended that the June 13 Occupational Safety and Health Administration (OSHA) memorandum addressed to you, on the inspection requirements of overhead crane hooks, be revised. We apologize for the delay in responding.
Based on a review of your request with respect to the attached ASME letter, with a view towards clarification, a determination has been made that a revision to OSHA's June 13 letter is warranted. We interpret 1910.179(j)(2), with respect to hooks, to mean that all hooks are subject to visual inspection by the operator or other designated person(s) at daily to monthly intervals. The daily to monthly inspection intervals for crane hooks shall be determined by the frequent and periodic inspection criteria of Section 2-2.1.1 through 2-2.1.3 of ANSI/ASME B30.2-1990 (attached). Inspection of hooks found to be deformed or cracked shall comply with .179(j)(2)(iii).
OSHA standard 1910.179(j)(2)(iii) and ANSI standard B30.2.0-1967, on which the OSHA standard is based, contain identical language that resulted in confusion as to the intent of the standards. Subsequent ANSI/ASME revisions to the 1967 standard (ANSI/ASME B30.2-1983/87 and 1990) resulted in further development and clarification, while the OSHA standard has not yet been modified. Your letter and the attached ASME letter will be referred to the Directorate of Safety Standards Programs for review and consideration for future rulemaking reference, particularly to clarify the language of the existing OSHA standard.
OSHA traditionally encourages employers to meet current national consensus standards which meet or exceed OSHA standards to enhance safety and health of employees in the workplace. As you are aware, OSHA, in most cases, cannot impose on employers more stringent safety and health requirements than promulgated in OSHA standards.
If you have additional questions, please let us know.