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.
June 30, 1995
Mr. Francis A. Scanlan
National Maritime Safety Association, Inc.
Post Office Box 120
Bryn Mawr, Pennsylvania 19010
Dear Mr. Scanlan:
This is in response to your May 22, letter addressed to Mr. Joseph A. Dear regarding a January 19 memorandum issued by the Office of Construction and Maritime Compliance Assistance.
The January 19 memorandum was issued in response to a report that sheaves on cranes had been refurbished by means of hand-grinding the sheaves in place using portable tools. The purpose of the memorandum was to provide guidance with respect to what constitutes an acceptable repair method, not to provide detailed tolerances and specifications for the examination and quantification of sheave damage. The related discussion was, therefore, limited in scope to an overview of what causes corrugated (wire rope imprint) damage to sheave grove surfaces, the available options (i.e., sheave resurfacing or replacement) and the principal factors which must be considered when resurfacing is the method of refurbishment. Within the context of the expressed purpose, the memorandum remains germane.
We appreciate your comments and interest in occupational safety and health.
John B. Miles
Directorate of Compliance Programs