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 19, 2005

Mr. Sal Insogna
Industrial Hygiene Consultant
Massachusetts OSHA Consultation Program
1001 Watertown Street
West Newton, MA 02465

Re: Safety chain requirements for pile driving hammer hoses.

Dear Mr. Insogna,

This is in response to your December 2, 2004, letter to the Occupational Safety and Health Administration (OSHA) asking for clarification of the requirements under 29 CFR 1926.603(a)(10) regarding safety chains for pile driving hammer hoses.

We have paraphrased your questions below:

Question 1: Does §1926.603(a)(10) apply to all hoses on pile driving hammers, including hydraulic hammers and hydraulic hammer power packs?

Answer: In 29 CFR 1926.603 (Pile driving equipment), paragraph (a)(10) states:

Safety chains, or equivalent means, shall be provided for each hose connection to prevent the line from thrashing around in case the coupling becomes disconnected.

 

The hazard addressed by this provision is that of workers being struck or injured by a hose should it "thrash" around if it comes loose from the equipment. By its terms, the provision is not limited to any particular type of pressurized system. Also, there is a thrashing hazard for disconnected hoses in pressurized hydraulic systems similar to that of equipment utilizing steam or compressed air. Therefore, the provision applies to hoses carrying pressurized hydraulic fluid on pile driving hammers.

The "power pack" pressurizes the fluid that operates the hammer and, therefore, is pile driving equipment subject to the applicable requirements of §1926.603. Some of the provisions in §1926.603 state that they apply only to certain parts of such equipment. For example, §1926.603(a)(9) contains requirements for "steam hose leading to a steam hammer or jet pipe" and for "air hammer hoses." However, §1926.603(a)(10) contains no such limitation, instead referring broadly to "each hose connection." Therefore, (a)(10) applies to hose connections at the power pack as well.

Question 2: What constitutes "equivalent means" as discussed in §1926.603(a)(10)?

Answer: As indicated above, §1926.603(a)(10) requires a safety chain or "equivalent means" to prevent a hose from "thrashing around" in the event of a disconnect between the hose and the equipment. The standard was written this way to give employers flexibility in using or developing other methods by which to prevent the thrashing hazard. Thus, any means which would effectively reduce the hazard to the same extent or better than a safety chain would constitute equivalent means. If you have a particular method on which you would like guidance regarding this provision, we would be happy to comment on it.

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,


Russell B. Swanson, Director
Directorate of Construction