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.

November 2, 1993

Mr. Robert A. McAdoo
Safety Director
Basin Electric Power Cooperative
1717 East Interstate Avenue
Bismarck, North Dakota 56501-0664

Dear Mr. McAdoo:

Thank you for your inquiry of May 5, addressed to Bruce C. Beelman, Area Director for the Occupational Safety and Health Administration (OSHA) in Bismarck, North Dakota requesting information as to whether rated load testing is required for engineer designed I-beams and attachments from which an underhung lifting device trolley is suspended. Your letter was forwarded here for response. Please accept our apology for the delay in responding.

Underhung trolley/lifting devices are excluded in the scope of application in Section 2-0.1 at ANSI 30.2 - 1967, required by 29 CFR 1910.179(b)(2) to meet the design specifications of the overhead and gantry cranes.

Section 5(a)(1) of the Occupational Safety and Health (OSH) Act, however, requires that each employer furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death of serious physical harm to employees.

OSHA considers exposure of employees to the risk of injury due to possible failure of support components of underhung trolley/lifting devices to be a recognized hazard. Rated load testing is one way in which employees may be protected against this hazard. For practical purposes, this means that employees utilizing underhung trolley/lifting devices must conduct "rated load tests" prior to initial use on all new, extensively repaired, and altered underhung trolley/lifting devices in the workplace. These tests are required to verify the loading capacity of the underhung trolley/lifting devices, as installed. The tests must be performed after the device is installed on the supporting structures (including I-beams) and connectors. Independent testing of I-beams and attachments is not required. Test loads must not be more than 125% of the manufacturer's rated load unless otherwise recommended by the manufacturer. The resulting load rating for the hoist must not be more than 80% of the maximum load sustained during the test. These requirements would not be applicable in working situations where employees would never be exposed to potentially falling hoist components, loads or supporting elements.

The above requirements are taken from ANSI/ASME standard B30.17d - 1990, Section 17 - 2.22 Rated Load Test. Although this is not an OSHA standard, and is not incorporated by reference in any OSHA standard, we believe the provisions must be followed even though B30.17d appears to be advisory in nature, utilizing "should" rather than "shall" constructions in its text. OSHA's policy, however, is to allow this particular provision to be understood as mandatory. The general policy allowing this is addressed by the OSHA Field Operations Manual at Chapter IV, A.2.d.(4), which allows the should portions of ANSI standards which are not predecessors to section 6(a) standards to be cited as an OSH Act Section 5(a)(1) violation in the presence of a serious hazard. We believe the potential collapse of an underhung trolley/lifting device is a serious hazard.

Thank you for your interest in occupational safety and health. If we may be of further assistance please contact us.


Roger A. Clark, Director
Directorate of Compliance Programs