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.

January 16, 1976

Mr. William Mueller
Chief Engineer
Utility Body Company
901 Gilman Street
Berkeley, California 94710

Dear Mr. Mueller:

This is in response to your letter of October 30, 1975 addressed to Mr. Gillotti, Regional Administrator of our San Francisco Region, regarding a clarification of 29 CFR 1926.556(b)(1), Ladder Trucks. In addition, it confirms your conversation with a member of my staff concerning this clarification.

[29 CFR 1926.453(b)(1)] reads as follows:

Ladder trucks and tower trucks. Aerial ladders shall be secured in the lower traveling position by the locking device on the top of the truck cab, and the manually operated device at the base of the ladder before the truck is moved for highway travel.

The requirements of this standard for a manually operated device was not intended to exclude the use of other devices which would be equally safe. This standard does require certain safeguards to be taken with applicable devices on aerial lifts that are equipped with these devices.

If I can be of any further assistance, please feel free to contact me.

Sincerely,


Barry J. White
Associate Assistance Secretary for Regional Programs

[Corrected 05/28/2004]