Whether unloading a pallet suspended by a crane is considered construction.

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.

June 23, 2016

John Kosta
Tiffin Loader Crane
4151 West State Route 18
Tiffin, OH 44883

Dear Mr. Kosta:

Thank you for your November 22, 2010, letter 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.

Clarification of whether the handling of propane tanks is considered construction

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.

June 27, 2016

Mr. Robert F. Helminiak
Director, Regulatory Affairs
National Propane Gas Association
1899 L Street, NW, Suite 350
Washington, DC 20036

Re: Cranes; 29 CFR 1926.1400(c)(17); delivery; Propane gas; articulating/knuckle-boom cranes

Dear Mr. Helminiak: