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.

October 15, 2014

Charlie Bird
Balfour Beatty Construction
1148 Harbour Point Drive
Port Orange, FL 32127

Dear Mr. Bird:

Thank you for your October 27, 2013, email to the Occupational Safety and Health Administration (OSHA) in which you ask for an interpretation of the Cranes and Derricks in Construction standard. We have paraphrased your question as follows.

Question #1: The term "assembly/disassembly" is used in §§ 1926.1403 - 1926.1406 for requirements particular to assembling and disassembling (A/D) the equipment. "Set-up" is used in § 1926.1402 regarding requirements particular to ensuring adequate ground conditions beneath the equipment. I have encountered situations on jobsites when it was interpreted that that A/D includes when any part that requires a bolt or pin to connect, including pinning/bolting outrigger floats/pads and swing away extensions. Are activities like these covered by §§ 1926.1403 - 1926.1406?

Answer: Generally, no. "Assembly/Disassembly" or A/D means the assembly and disassembly of equipment covered under this standard and the complexity of preparing and putting together sections and/or parts of a crane at a construction site may vary depending on the model of the crane. Some cranes come to the site fully assembled and A/D is not needed. Some models of truck cranes require relatively simple assembly of the boom. Other cranes require complex assembly such as adding counterweights or attachments, attaching outriggers/stabilizers, or using an assist crane to position the boom or jib for pinning/unpinning.

In contrast, OSHA considers "set-up" as involving the deployment of an assembled crane. For example, set-up includes activities like deploying and pinning outriggers, leveling the equipment, or unfolding and pinning a boom or swing-away jib and not assembly. As you note, the set-up requirements of the standard address the stability of the crane by ensuring adequate ground conditions. For example, § 1926.1402(c)(2) requires that the user be informed of hazards beneath the set-up area, and § 1926.1431(c) requires level ground conditions and use of any outriggers and/or stabilizers.

Question #2: Does OSHA specify any further criteria, such as that of an annual inspection, for a post-assembly inspection other than the verification of the crane's configuration in accordance with the manufacturer's or qualified person's (when manufacturer's procedure are unavailable) equipment criteria?

Answer: No. The post-assembly inspection is only meant to ensure that the crane has been configured and assembled correctly before put into service.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,

James G. Maddux, Director
Directorate of Construction