Standard Interpretations - Table of Contents
• Standard Number: 1910.272(p)(4)(ii)

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

October 31, 1991

Mr. Kevin J. Schultze
Continental-Agra Grain Equipment, Inc.
1400 South Spenser Road
Post Office Box 525
Newton, Kansas 67114

Dear Mr. Schultze:

This is in response to your April 18 letter with supporting information enclosures requesting interpretations and clarifications of 29 CFR 1910.272 as delineated in Occupational Safety and Health Administration (OSHA) Instruction, [CPL 02-01-004] on Grain Handling Facilities. Please accept our apology for the delay in response.

Your first request is to clarify the terminology "making contact with the interior leg casing" in [CPL 02-01-004 (formerly CPL 2-1.4C), paragraph 19] which interprets the "partially inside the leg" terminology of the 29 CFR 1910.272(p)(4)(ii) bearing monitor standard. Note that bearings can be installed inside, partially inside or externally with respect to the leg casing of bucket elevators. Therefore, 29 CFR 1910.272(p)(4)(ii) is interpreted to require bearing monitoring unless the bearing assembly including associated inner dust seals are installed externally, that is, without touching, to the leg casing. Also, not