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 29, 2015

Mr. Patrick E. Wall, Engineering Supervisor
Gorbel, Inc.
600 Fishers Run
PO Box 593
Fishers, NY 14453-0593

Dear Mr. Wall:

Thank you for your March 25, 2015 correspondence to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs. You requested information on OSHA requirements for grounded contact conductors on overhead traveling crane systems. Your question, and our reply, follow.

Scenario: Your organization manufactures an overhead crane rail system that has insulated crane contact conductor rails. All conductors in the system have orange covers, including the grounded contact conductors.

Question: Does OSHA require green covers for grounded contact conductors in overhead traveling crane systems?

Response: No, OSHA does not require green covers on grounded contact conductors in overhead traveling crane systems. However, OSHA’s Overhead and Gantry Cranes standard, at 29 CFR 1910.179(g)(1)(i), requires, with respect to overhead cranes, that wiring and equipment comply with 29 CFR Part 1910, Subpart S. And Subpart S, at 29 CFR 1910.304(a)(1), requires that any conductors used as grounded conductors, or as equipment grounding conductors, must be “identifiable and distinguishable from all other conductors.” Therefore, to comply with the standard you must identify the grounded conductor in a manner that makes it clearly distinguishable from ungrounded conductors. One way to do this would be to use a different color for the covers on the grounded conductor.

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. 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 https://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

 

Thomas Galassi, Director
Directorate of Enforcement Programs