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.

September 26, 1996

Mr. John R. Molovich
United Steelworkers of America
Five Gateway Center
Pittsburgh, PA 15222

Dear Mr. Molovich:

This is in response to your September 19 request for interpretation of the overhead and gantry cranes standard, 29 CFR 1910.179. The scenario described in you letter, your question and our reply follow.

Scenario: A steel plant has two four hundred and fifty ton overhead cranes. Both of these cranes are operated at near capacity while handling molten metal. The following test was performed. One of the cranes was operated to lift an empty ladle some 15 feet off the floor. The crane operator placed the hoist controller in the first contact point in the lowering position. Then the crane operator pulled the main power switch (located in the cab)removing power from the hoist control circuit. The downward motion of the ladle did not stop until the crane operator moved the hoist controller to the neutral, center position. The aforementioned test and the result was communicated to company officials who advised, based on controller manufacturer information, that the controller would have to be placed in the neutral, center position to stop the downward movement of the ladle upon loss of power.

Question: Does the overhead crane described in the preceding scenario meet the holding brake requirement of paragraph 1910.179(f)(2)(iii)?

Reply: If the crane is equipped with holding brakes which are not designed to be applied automatically, the employer would be in violation of paragraph 1910.179 (f)(2)(iii). If the crane is equipped with holding brakes which are designed to be applied automatically when the power is removed and does not do so and the crane is continued in service without adjustment or repairs, the employer would be in violation of paragraph 1910.179(l)(3).

Thank you for your interest in employee safety and health. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202) 219-8031, extension 110.


Michael G. Connors
Deputy Assistant Secretary