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.

January 11, 2001

Mr. Alan Colinet
Crane Pro Services
1314 East Philadelphia Ave.
Gilbertsville, PA 19525

Dear Mr. Colinet:

Thank you for your April 14, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs]. You requested review of a September 17, 1990 letter of interpretation and asked for a generic interpretation as to whether the letter continues to reflect current OSHA policy. Specifically, you asked whether the interpretation prohibiting the use of a load-limiting device as a top stop device on a Yale KEL hoist can be applied to all hoists using the same method.

The September 17, 1990 letter of interpretation you reference no longer reflects OSHA policy. Currently, we allow the use of load-limiting clutches as upper and/or lower limit devices, provided the load-limiting clutch and/or other parts of the hoist that function as the limit device are designed by the manufacturer of the hoist for such operation.

A review of American Society of Mechanical Engineers (ASME) B30.16, Overhead Hoists (Underhung) defines limit device as "a device that is operated by some part or motion of a power driven hoist to limit motion." Section B30.16-1.2.14, Overtravel Protection states "The hoist shall be so designed and constructed that the load hook, either loaded or empty, shall not exceed the upper limit of travel." Section B30.16-1.2.1(a) states "The hoist and appurtenances shall be designed to withstand all stresses imposed under normal operating conditions while handling loads within the rated load (capacity)." As such, as long as the hoist is designed, constructed, utilized, and maintained in accordance with ASME B30.16, OSHA would consider the use of a load-limiting device as an upper limit travel stop device to be in compliance with OSHA regulations and the general duty clause of the Occupational Safety and Health Act of 1970.

Thank you for your interest in occupational safety and health. We hope you find this provides the clarification you were seeking and apologize for any confusion the earlier documents may have caused. In the future, should you wish to verify that the guidance 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.

Sincerely,


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Correction 10/15/2003]