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.

June 4, 2014

Mr. Michael J. Gelskey
Lift-It Manufacturing Company, Inc. 4780 Corona Avenue
Los Angeles, CA 90058-3808

Dear Mr. Gelskey:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry and Agricultural Enforcement (OGIAE) for an answer to your question regarding vertically lifting compressed gas cylinders using a Gas Cylinder Cradle that is manufactured by your company. This constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Your question is whether using the "Lift-It CG 10A, 20A, 30A, Gas Cylinder Cradle" that is manufactured using a leather lined nylon pocket (http://www.lift-it.com) constitutes a violation of 29 CFR 1910.253(b)(5)(ii)(A). This standard states that "when transporting cylinders by a crane or derrick, a cradle, boat, or suitable platform shall be used. Slings or electric magnets shall not be used for this purpose."

In accordance with 29 CFR 1910.184, the definition of a sling is "an assembly which connects the load to the material handling equipment." After conducting a search of your website, your company indicates the Gas Cylinder Cradle as a type of sling. Moreover, the picture of your Gas Cylinder Cradle system fits OSHA's definition of a sling. Therefore, if an employer were to use your Gas Cylinder Cradle to lift compressed-gas cylinders, OSHA would consider this to be a violation of 29 CFR 1910.253(b)(5)(ii)(A).

Lastly, twenty-seven states, including California, operate their own occupational safety and health programs approved by OSHA. States enforce similar standards that may have different or additional requirements. A list of state plans is available at https://www.osha.gov/dcsp/osp/index.html.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely

Thomas Galassi,
Directorate of Enforcement Programs