February 18, 1992
MEMORANDUM FOR: LINDA ANKU
THROUGH: LEO CAREY, Director Office of Field Programs
FROM: PATRICIA CLARK, Director Directorate of Compliance
SUBJECT: Cardiovascular Stress and the use of Crane or Derrick
Suspended Personnel Platforms
This memorandum is in response to your January 14, 1992, memorandum on the
above subject and will serve to confirm information provided to Messrs. T om
Pope, John McFee, and Joe Crawford when they visited the National Office on
January 27, 1992. Also in attendance at the January 27 meeting were Mr.
Gerald Reidy and Mr. Ted Twardowski of the Office of Construction and Civil
Engineering Safety Standards, Mr. Daniel Mick of the Office of the Solicitor,
Dr. Mike Montopoli of the Directorate of Technical Support, and Mr. Roy
Gurnham and Mr. Dale Cavanaugh of my staff in the Office of Construction and
Maritime Compliance Assistance.
At the meeting Mr. Pope stated that the deposition has been rescheduled for
February 12, 1992. Your concerns were then addressed and the following
- Exposure to cardiovascular stress is only one of many factors
to be assessed when making the decision to use or not to use a crane- or
derrick-suspended personnel platform (CDSPP). For example, another factor is
whether or not other personnel are available to do the work. However,
assuming for the sake of argument, that a particular employee has been
thoroughly examined by a physician and a determination made by the physician
that the employee should use a CDSPP because of cardiovascular risk, all
other employees would still be required to use conventional means of access,
such as stairs, thus minimizing the exposure to the hazards of using a
- An employer is not required by OSHA to make employees take rest
breaks as they access elevated work stations by conventional means. However,
rest platforms must be provided as required by OSHA in order to provide
employees a place to rest when they so desire. As Dr. Montopoli pointed out,
if an employee has been diagnosed as having a cardiovascular problem, the
availability of rest platforms may not be sufficient to disallow the use of
CDSPP for that individual. The total height of climb would also need to be
- In order to make a determination of the risk of exposure to
cardiovascular stress, the physician must examine each individual employee.
Only those found to be at risk would be allowed to use a CDSPP (assuming, as
stated in response 1. above, those individuals are needed to perform the
task). The physician must be given complete and detailed information on the
anticipated stress including, but not limited to, the number of steps, rate
of ascent, frequency of ascent, weight of equipment, and any other factors
the physician may deem necessary for a complete evaluation.
- Even if the examining physician determines that a particular
employee would be subject to cardiovascular stress, the employer must
consider whether reasonable changes can be made that will avoid the risk.
For example, equipment can be hoisted rather than carried. Pre-planning and
modification of work schedules can possibly reduce the number of ascents
which an employee must make.
- Employers must endeavor to utilize employees who are not likely
to be exposed to excessive risk of cardiovascular stress while accessing
elevated work platforms only when the means of access poses such a threat.
the use of an elevator, for example, would not require such a policy.
However, this policy should not be used to require the hiring of new or
replaced employees. On the other hand, employers should anticipate the need
for climbing in their work when hiring new employees (including arrangements
with hiring halls).
As stated in your memorandum and in the preamble to the rule, "employee
safety, and not practicality or convenience must be the basis for the
employer's choice of method [of access]." Employers need to be reminded that
as a general rule, the practice of using a CDSPP is prohibited.
We are drafting a letter to McLean Construction Company that addresses these
and other points. We will forward you a copy for review prior to mailing.