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 16, 2007

Ms. Vicki L. Mills
Industrial Safety Lead
1448 SR 333
Russellville, AR 72802

Dear Ms. Mills:

Thank you for your December 14, 2006, email to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to the Directorate of Enforcement Programs (DEP) for response. You had specific questions regarding lifting devices on cranes. Your paraphrased questions and our responses are below. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence.

Question 1: When used in general industry, are load handling fixtures, such as lifting beams and other special fixtures, considered part of the load when they are pinned to the load block, raised, and then moved from one location to another on an overhead crane?

Response 1: Yes, these lifting devices are considered part of the load. OSHA previously faxed you a copy of a September 10, 2007, letter to Mr. Stan W. Kadlec, which discusses the same issue. As stated in that letter, "The OSHA standard on overhead and gantry cranes, §1910.179, defines a load as 'The total superimposed weight on the load block or hook.' Since below the hook devices or slings would be part of the weight on the load block or hook, these would be considered a suspended load."

Question 2: In general industry, is it permissible for such load handling fixtures to be hoisted over personnel?

Response 2: No. As stated in the standard for Overhead and Gantry Cranes, §1910.179(n)(3)(vi), "The employer shall require that the operator avoid carrying loads over people." Since these fixtures are considered to be loads, they are not permitted to be hoisted over personnel.

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 http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at 202-693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs