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.

March 22, 1995

Mr. Gary J. Amsinger
Corporate Safety Director
McCarthy - Bridge and Heavy Division
1341 North Rock Hill Road
St. Louis, Missouri 63124-1498

Dear Mr. Amsinger:

This is in response to your January 24 letter requesting a statement of compliance from the Occupational Safety and Health Administration (OSHA) concerning your proposed method of maintaining a safe working perimeter outside a crane's swing radius as specified in CFR 1926.550(a)(9).

If used as described in your letter and as shown in the accompanying illustration, the 3" barricade warning tape mounted on the crane would meet Federal OSHA's requirements for barricading the swing radius of a crane's superstructure.

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.


Roy F. Gurnham, P.E., J.D.
Director Office of Construction and Maritime Compliance Assistance


January 24, 1995

Mr. Roy Gurnham, Director
Office of Construction/Maritime Compliance Assistance
U.S. Department of Labor - OSHA
200 Constitution Avenue, N.W.,
Room N-3610
Washington D.C. 20210

RE: Crane Swing Protection, 1926.550,a,9

Dear Mr. Gurnham,

At a 500 level training course, in St. Louis, we discussed the different methods of complying with the above referenced regulation. As a major Contractor in the U.S., we have performed work all over the country and have been subject to different interpretations of this regulation by different Area Offices. To aid McCarthy in complying with this rule nationwide, I was hoping we could implement a simple, but effective means to properly warn employees of this hazard.

This method uses a nondestructive method of attachment to the cranes, as the majority of our equipment is rental, and we are not allowed to alter the equipment.

The method I envision mounts on the crane and maintains a safe working perimeter around the crane utilizing 3" barricade warning tape, similar to that used by authorities to secure an area of a crime scene, and similar to the attached advertisement. It would be used also on crawler cranes, as they represent a greater hazard than the rough terrain shown, and move just as much.

Please review to determine if this type of perimeter barricade would meet the intent of the regulation.

If you think you may need to see some type of detailed schematic of this setup please advise, or wish to call discuss please do so.

Thank you in advance for your thoughts on this subject.

Your attention to this matter is greatly appreciated.


Gary J. Amsinger
Corporate Safety Director


(For Figures 1 through 3, see printed copy)