- 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.
November 27, 2007
Mr. Edward Squibb, CSP
Project Safety Coordinator
Daniel J. Keating Company
134 N. Narberth Ave.
Narberth, PA 19072
Re: Whether under §1926.550, a crane may be left unattended with its spreaderbar suspended; where in §1926.550 of Subpart N, other than in §1926.550(g), is the use of tag lines referenced; how are "cable lugs" used under §1926.351(b)(3).
Dear Mr. Squibb:
This is in response to your letter dated November 28, 2005, to the Occupational Safety and Health Administration (OSHA). You asked about requirements in the construction standards relative to: unattended cranes with suspended spreading bars: tag lines; and the use of cable lugs to make connections under §1926.351(b)(3). We apologize for the long delay in responding.
We have paraphrased your questions as follows:
Question (1): Scenario: a crane operator leaves a crane for a short period of time (i.e., for a lunch break) with its spreader bar suspended. Do OSHA construction requirements prohibit the operator from leaving the controls in that situation?
Answer (1): Section 1926.550(b)(2) provides:
All crawler, truck, or locomotive cranes in use shall meet the applicable requirements for design, inspection, construction, testing, maintenance, and operation as prescribed in the ANSI B30.5-1968, Safety Code for Crawler, Locomotive, and Truck Cranes.
ANSI B30.5-3.1.2 (1968) states:
(f). Before leaving his crane unattended, the operator shall: 1. Land any attached load, bucket, lifting magnet, or other device. 2. Disengage clutch. 3. Set travel, swing, boom brakes, and other locking devices. 4. Put controls in the "off" position. 5. Stop the engine. 6. Secure crane against accidental travel. 7. When wind alarm is given or on leaving crane overnight, rail clamps, where provided, shall be set on locomotive cranes and ground chocks set on truck or crawler cranes. 8. Crane booms shall be lowered to ground level or otherwise fastened securely against displacement by wind loads or other. [Emphasis added]
Similarly, ANSI B30.5-3.2.4(a) (1968) states:
The operator shall not leave his position at the controls while the load is suspended.
Finally, Section 5-0.2.2.25 of ANSI B30.5 (1968) defines "load (working)" as:
The external load, in pounds, applied to the crane, including the weight of load-attaching equipment such as load blocks, shackles, and slings. [Emphasis added].
A spreader bar is a load attaching device. It, therefore, is included as an "other device" under ANSI B30.5-3.1.2 (1968), paragraph (f) 1., and included in the definition of load under the definition quoted above. Thus, by their terms, these provisions prohibit an operator from leaving a crane "unattended"1 or from leaving the controls of a crane, with a suspended spreader bar.
Question (2): Where in §1926.550 of Subpart N2, other than in the provisions related to suspended personnel platforms, is the use of "tag lines" mentioned?
Answer (2): As stated above, Section 1926.550 incorporates by reference ANSI B30.5-1968. In addition to the suspended personnel platform provision that you mentioned, ANSI B30.5-1968, Section 5-3.2 (p) states:
When rotating the crane, sudden starts and stops shall be avoided. Rotational speed shall be such that the load does not swing out beyond the radii at which it can be controlled. A tag or restraint line shall be used when rotation of the load is hazardous. [Emphasis added]
Question (3): Section 1926.351(b)(3) refers to "cable lugs." Do the requirements of this provision apply when cable lugs are used to connect cables to welding machines or, as it appears, to connect (i.e., splice) one cable length to another cable length?
Answer (3): Section 1926.351(b) Welding cables and connectors provides in part:
(3) When it becomes necessary to connect or splice lengths of cable one to another, substantial insulated connectors * * * shall be used. If connections are effected by means of cable lugs, they shall be securely fastened together to give good electrical contact * * *. [Emphasis added]
By its terms, this section applies to the connection or splicing of lengths of cables, "one to another," not to the connection of a cable to the welding machine.
If you need additional clarification on this subject, please contact us by fax at: U.S. Department of Labor, 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.
Steven F. Witt, Director
Directorate of Construction
1 "Unattended" is not defined in the standard, but see footnote 3. [ back to text ]
2 Your letter did not clearly limit this question to any particular sections of 1926; since we were unable to contact you (and in view of the potential breadth of this question), we limited our response to §1926.550 of Subpart N. [ back to text ]