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.
March 23, 1992
Mr. Del Schimpf President
P.O. Box 998
Loveland, Colorado 80539
Dear Mr. Schimpf:
This is in response to your February 23 letter requesting the Occupational Safety and Health Administration (OSHA) to recognize the Dump Boss Monitoring System as an accurate and reliable method of safely unloading the end dump semi-trailer. I apologize for the delay of this response.
As explained at our meeting with you on 12 February, it is the policy of the Occupational Safety and Health Administration not to approve or endorse products. The variable working conditions at jobsites and possible alteration or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the product manufacturer. However, we have reviewed the information provided at the meeting and it appears the Dump Boss Monitoring System properly installed and maintained in accordance with the manufacturer's instructions, would provide an accurate and reliable method of safely unloading the end dump semi-trailers shown in your report.
If we can be of any further assistance, please contact Mr. Dale Cavanaugh of my staff at (202) 523-8124.
Patricia K. Clark, Director
Directorate of Compliance Programs