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 8, 1998

Jerry M. Gillooly
Safety Manager
Bohl Crane, Inc.
534 Laskey Road
Toledo, Ohio 43612

Dear Mr. Gillooly:

This is in response to your March 3 letter addressed to Mr. Roy Gurnham, Occupational Safety and Health Administration (OSHA) seeking an interpretation of 29 CFR §1926.502(d)(23) and guidance in identifying acceptable methods for accessing a crane runway from an aerial lift.

The referenced regulation prohibits personal fall arrest systems from being attached to guardrail systems or to hoists except as specified in other subparts of this part. This would apply to all guardrail excepting those that have been specifically designed for such use in accordance with the requirements of §1926.502(d)(15).

In the situation you described where suitable anchorage points are not provided for on cranes, employers are to be guided by §1926.502(a)(2), which instructs them to provide and install all fall protection systems for employees and comply with other pertinent subpart requirements before the employee begins work that necessitates the fall protection. Simply put, in situations where the status of appropriate anchorages are unknown or suspected to be inadequate, employers should discuss safe ways to access crane runways and other areas where work is to be conducted. Such planning should anticipate where proper anchorages are to be located prior to work being started instead of using alternative anchorage points which may not comply with this subpart.

If you require any further assistance, please do not hesitate to contact us again by writing to: Directorate of Construction - OSHA, Office of Construction Standards and Compliance Assistance, Room N3621, 200 Constitution Avenue, N.W., Washington, D.C. 20210

Sincerely,

Russell B. Swanson, Director
Directorate of Construction