- Standard Number:
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.
|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.|
November 8, 1999
Dear Mr. Borum:
Thank you for your September 10, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). You have questions regarding the applicability of §1910.178(l) Powered Industrial Truck operator training to "Travel Lift" operators. Your specific questions have been restated below for clarity.
Questions. What is OSHA's actual position on travel lift training for the December 1999 deadline? What rule applies?
Response. In your letter, you mention that you have an Acme 25-ton Travel Lift that is used to lift boats from the water for service. You stated that the travel lift is inspected yearly in accordance with 29 CFR §1910.179 and the American National Standard Institute (ANSI) B30.2 Overhead and Gantry Cranes. In addition, you provided manufacturer's information on a Marine Travelift Inc., Mobile Boat Hoist which you stated was a typical travel lift.
Based on the information you provided, a "travel lift" which is manufactured, maintained, operated, and inspected in accordance with ANSI B30.2 would be considered as a "mobile gantry crane." OSHA''s Overhead and gantry crane standard, §1910.179 would be applicable for this type of equipment. Therefore, the powered industrial truck operator training standard with the December 1999 training compliance date would not be applicable.
However, please be advised that 29 CFR 1910.179(b)(8) requires that only designated personnel be permitted to operate a crane. OSHA defines designated at 1910.179(a)(35) as:
Selected or assigned by the employer or the employer's representative as being qualified to perform specific duties [emphasis added].
Because the term "qualified" is not itself defined, OSHA would interpret "qualified" in light of operator-qualifications provisions of industry standards such as ANSI B30.2. Although the 1910.178 training requirements do not apply, you may also find it useful to consult that standard when developing a training or evaluation program for "travel lift" operators.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.
Richard E. Fairfax, Director
Directorate of Compliance Programs