Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

May 11, 1992

Mr. Scot Litke
Executive Director
The International Association of
Foundation Drilling
P.O. Box 280371
Dallas, Texas 75228/


Dear Mr. Litke:

This is in response to your March 20 letter and resolution concerning the Occupational Safety and Health Administration's (OSHA) standards addressing mobile crane-hoisted boatswain chairs. I apologize for the delay in responding to you.

As you point out in your letter, OSHA does not have all inclusive standards specific to drilled shaft entry and therefore has applied more general standards to address the hazards associated with drilled foundation activities. Although you have stated that you believe your operations are inappropriately being viewed as falling under diverse regulations, there are in fact, confined space, excavation, personnel transportation, and other concerns when entering drilled foundation shafts. OSHA's past practice has been to promulgate general safety and health standards that apply to all construction operations (e.g., hard hat requirements). When OSHA does promulgate operation-specific standards, it addresses hazards unique to that operation. while we recognize that your type of operations are somewhat unique, the Agency believes that existing standards adequately address the hazards associated with them. Until OSHA promulgates a specific standard (not presently being considered), OSHA must rely on other standards addressing the hazards inherent to those operations.

OSHA's regulations concerning the use of cranes for lifting personnel are relatively new, having been published in August, 1988,. During this rulemaking, the International Association of Foundation Drilling (ADSC) did not submit comments so the Agency is not aware of the specific reasons that a personnel platform cannot be designed for this use, is not feasible, or if the use of a personnel platform would create greater hazards. While the Agency is aware that cranes have been traditionally used to hoist and suspend personnel in boatswain chairs in the drilled foundation industry, these operations, as well as all employers, are bound by the requirements of section 1926.550(g) unless sufficient justification as explained above is provided.

Please be assured that OSHA will be happy to provide as much assistance as possible to the ADSC "Task Force" in their effort in developing industry procedures and practices. If additional assistance is desired, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance. Their telephone number is (202) 523-8136.



Dorothy L. Strunk
Acting Assistant Secretary