Clarification on cranes standard regarding railroad equipment controlling entity's duty to disclose known ground-condition hazards and about the process of communicating the location of subterranean hazards to operators.
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.
November 14, 2014
Jill Hyman Kaplan, Esq.
Counsel for the Association of American Railroads
Manko, Gold, Katcher & Fox, LLP
401 City Avenue, Suite 901
Bala Cynwyd, PA 19004
Dear Ms. Hyman Kaplan: