Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

July 20, 2000

Mr. Ian P. Carvajal
Saldana & Carvajal, P.S.C.
361 San Francisco Street
Third Floor
San Juan, Puerto Rico 00901

Dear Mr. Carvajal:

Thank you for your May 31, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) Puerto Rico Area Office. Your letter has been referred to the Directorate of Compliance Programs for an answer to your specific question regarding the applicability of 29 CFR Part 1917.46(a)(1)(viii)(A) to the crane described in your letter and the attached photographs. The standard states:

"The load indicating device requirements of this subparagraph do not apply to a crane: (A) Of trolley equipped bridge type or overhead type while handling intermodal containers known to be identified as empty, or loaded, and in either case in compliance with the provisions of 29 CFR Part 1917.71..."

Please be advised that OSHA does consider the PACECO Crane in question to be a trolley equipped bridge crane and is therefore, exempted from the Load Indicating Device requirement.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that the enforcement guidance contained in this response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at If you have any further questions, please feel free to contact the [Office of Maritime Enforcement at (202) 693-2399].


Richard Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]