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.
February 12, 1991
Mr. Neal R. Khein, Jr.
Material Handling Systems, Inc
720 S.W. 4th Court
Dania, Florida 33004-3803
Dear Mr. Khein:
This is in response to your letter of December 18, 1990 in which you inquired about Occupational Safety and Health Administration (OSHA) standards that may apply to monorail systems and underhung cranes, as outlined in ANSI B30.11-1980.
In order for your systems to be in compliance, the manufacture of your product would need to be in conformance with the design and construction criteria set forth in ANSI B30.11-1980. This is the applicable standard.
While OSHA as yet has no standard of its own covering monorail systems and underhung cranes, under Section 5(a)(1) (the general duty clause) of the Occupational Safety and Health Act all employers have a legal responsibility to provide safe and healthful workplaces for their employees. OSHA's policy is that the general duty clause requires employers to comply with safety standards recognized in the industry, such as ANSI B30.11-1980. The purchasers and users of your product will expect you to manufacture them to be in compliance with the requirements of OSHA.
Your interest in safety and health is appreciated. If we may be of further assistance, please do not hesitate to contact us.
Sincerely,
Patricia K. Clark, Director
[Directorate of Enforcement Programs]
[Corrected 10/22/2004]