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 https://www.osha.gov.

April 6, 1993

Colin J. Brigham, CIH, CSP
Loss Control Manager
EBI Companies
Four Greenwood Square
3325 Street Road
Suite 220
Bensalem, PA 19020

Dear Mr. Brigham:

This is in response to your question concerning whether overhead bridge cranes and gantry cranes, regulated by OSHA Standard 29 CFR 1910.179, can be used as work platforms. Work, such as servicing of overhead lights, would be performed from such cranes.

Work cannot be performed from a suspended load or hook but otherwise may be done from the types of cranes referenced in the preceding paragraph. However, such work may be performed only if all the following conditions are met:

1. Fall protection and standard guardrails shall be provided and used.

2. Ladders shall not be erected and/or used on cranes to gain access to areas that are not directly accessible from a crane without the use of a ladder.

3. Only "qualified persons," as that term is defined at 29 CFR 1910.399, shall be permitted to perform work on or near electrical equipment.

4. Machinery and live electrical equipment shall be guarded.

5. Work from cranes shall be performed only when a crane is stationary.

6. Crane operators shall be notified before work is performed from a crane.

7. A crane shall not be moved until all employees on the crane are in locations where they will not be exposed to injury.

8. Crane operators shall not move a crane unless they have determined that all personnel are located in areas where they will not be exposed to injury.

9. Rail stops or other suitable methods shall be used to prevent a crane from being struck, whenever other cranes are in operation on the same runway.

10. Signs, which indicate work is being performed, shall be posted whenever work is performed from a crane. Such signs shall be visible from the floor.

11. Lockout/Tagout procedures shall be implemented, as appropriate, when work is being performed from a crane.

12. Safe egress to and from a crane shall be provided.

If you require any additional information regarding the preceding, please contact John McFee of my staff at (215) 596-1201.


Regional Administrator