- OSH Act:
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 19, 2014
Mr. Steve Green
1932 Jordache Court
Gastonia, North Carolina 28052
Dear Mr. Green:
Thank you for your letter dated July 7, 2014, to the Occupational Safety and Health Administration (OSHA) regarding applicable OSHA standards for automotive lifts. 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 paraphrased and our response follows.
Scenario/Background: Nussbaum Automotive Solutions is a manufacturer of automotive service equipment based in Gastonia, North Carolina. Your products include automotive lifts used in many car dealerships and vehicle service facilities across the United States and Canada. Your customers have communicated their concerns regarding OSHA compliance when it comes to the equipment they purchase. You want to do everything possible to ensure that the automotive lift equipment that you provide to your customers is safe when used and maintained properly according to manufacturer's instructions.
Question: Are there any specific OSHA standards that apply to automobile lift users for OSHA compliance?
Reply: No. OSHA does not have any specific standards that apply to a user of automotive lifts. In cases where no specific OSHA standard applies to a safety and health condition in a workplace, an employer is still under an obligation to provide a workplace that is free from recognized hazards that are likely to cause death or serious physical harm pursuant to Section 5(a)(1) of the Occupational Safety and Health Act of 1970 ("the General Duty Clause").
As you are aware, the ANSI/ALI ALOIM: 2008, Standard for Automotive Lifts - Safety Requirements for Operation, Inspection and Maintenance is the industry recognized consensus standard for employers operating automotive lifts. While OSHA does not enforce standards from other standards-setting bodies or non-governmental organizations, unless incorporated by reference into an OSHA standard or adopted as an OSHA standard, national consensus standards and manufacturers' recommendations may be used as evidence of hazard recognition and the availability of feasible means of abatement in cases where an employer is cited for a violation of the General Duty Clause.
Question#2: Do OSHA standards require the automobile lift manufacturer to certify lifts to the ANSI/ALI ALCTV-2011 - Standard for Automotive Lifts - Safety Requirements for Construction, Testing and Validation?
Response #2: No. There are no OSHA standards that contain certification requirements for automotive lifts.
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 assure that you are using the correct information and guidance, please consult OSHA's website at https://www.osha.gov. If you have further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.
Thomas Galassi, Director
Directorate of Enforcement Programs