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.

November 3, 2005

Mr. Peter Doskey
Hoist & Crane Service Group
9221 Raton Avenue
Baton Rouge, Louisiana 70814

Dear Mr. Doskey:

Thank you for your June 22, 2005, letter to the Occupational Safety and Health Administration's (OSHA) Dallas Regional Office. Your letter was referred to the Directorate of Enforcement Program's (DEP) Office of General Industry Enforcement for an answer to your questions regarding OSHA's Overhead and Gantry Crane Standard, 29 CFR 1910.179. Your question has been restated below for clarity.

Background: 29 CFR 1910.179(h)(2)(iii)(a) states "No less than two wraps of rope shall remain on the drum when the hook is in its extreme low position."

Question: When the hook is in its extreme low position, does this mean that the hook is at its lowest point of travel when all of the rope has been unwound, except for the required wraps or does this mean that the hook must be capable of traveling all the way to the ground with no load with the required wraps?

Reply: Although the term "extreme low position" is not specifically defined in 29 CFR 1910.179, nor in its source standard, American National Standard Safety Code for Overhead and Gantry Cranes, ANSI B30.2.0-1967, the extreme low position would be the lowest point possible that the hook could rest on the ground or floor while maintaining at least two wraps of rope. The requirements in the standard are designed so that sufficient and properly fastened rope remains on the drum and the rope does not slip off the drum.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. In addition, 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. If you have any further questions, please feel free to contact the General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs