November 10, 1993

Mr. Al Willis
Safety Director
Barnard Construction Company, Inc.
P.O. Box 99
Bozeman, Montana 59771-0099

Dear Mr. Willis:

This is in response to your August 31 letter requesting a compliance determination from the Occupational Safety and Health Administration (OSHA) regarding the acceptability of load testing a crane to 110% of its capacity in order to meet contractual requirements. I apologize for the delay in responding to your inquiry.

As stated in the August 23, 1993, letter to you from Mr. Timothy Ritter of Grove North America, OSHA does not require a routine test that exceeds the rated capacity of the crane. Overload tests are only required of new cranes and after the crane has been repaired or rerated. Therefore, all other overload tests must be performed according to the manufacturers specifications and limitations as required by 1926.550(a)(1).

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,



Roy F. Gurnham, P.E., Esq.
Director
Office of Construction and Maritime
Compliance Assistance




August 31, 1993

Director of Compliance Assistance
U.S. Department of Labor - OSHA
200 Constitution Ave., N.W. Room N3610
Washington, DC 20210

Dear Sir:

We have a request by the Bureau of Reclamation (BOR) to load test cranes to 110% of capacity. I have requested information from two crane manufacturers to see if we can do this. My understanding from the answers is we can load test cranes to that capacity if the test is to meet requirements for ANSI B 30.5.

A copy of correspondence with the two crane manufacturers and an excerpt of the section of Construction Safety Standards of the BOR are enclosed.

Will we be within OSHA standards to load test a crane to 110% capacity for contractual requirements which are not part of meeting ANSI B 30.5?

Sincerely,



Al Willis
Safety Director




August 9, 1993

Grove Manufacturing Company
Box 21
Shady Grove, PA 17256

Dear Sir:

We have been requested by an owner we work for to load test each of our cranes to 110% of their rated capacities.

As you are probably aware: OSHA 1926.550(a)(1) states:

"The employer shall comply with the manufacturer's specifications and limitations applicable to the operation of any and all cranes and derricks."

We read in your operator's manual not to exceed the rated capacity of the crane. I have two questions:

1. Is making a test lift of 110% exceeding the rated limitation capacity of the crane?

2. If it is exceeding the limitations rating of the crane, may we have permission to test lift to 110% of the crane's capacity so we will be in compliance with OSHA 1926.550(a)(1)?

Sincerely,



Al Willis
Safety Director




August 23, 1993

Barnard Construction Company, Inc.
P.O. Box 99
Bozeman, MT 59771-0099

Attention: Al Willis

RE: "Overload" Testing - Grove Cranes

I am responding to the questions from your 9 August 1993 letter:

1 - "Is making a test lift of 110% exceeding the rated limitation capacity of the crane"?

RESPONSE: The capacities printed on a Grove crane's load chart are the maximum rated capacities for that crane. Lifting 110% of a rated capacity value for a given crane set-up configuration would be exceeding the capacity of the crane.

2 - "If it is exceeding the limitations rating of the crane, may we have permission to test lift to 110% of the crane's capacity so we will be in compliance with OSHA 1926.550(a)(1)"?

RESPONSE: Neither OSHA nor Grove requires any type of routine load test where it is necessary to exceed a crane's rated capacity. Overload testing is only required as a proof test when the crane is first built and when the crane is repaired or rerated. Any overload testing that must be done after repairs and re-rates of the crane can only be performed with the manufacturer's written permission and according to the manufacturer's guidelines. Any other type of "load testing" must be performed at 100% or less of the crane's rated capacity.

I hope that I have satisfactorily addressed your concerns. If you have any further questions regarding load testing please contact your local authorized Grove Distributor or Grove's Product Support department.

Sincerely,

GROVE NORTH AMERICA



Timothy A. Ritter
Product Safety & Reliability Engineer




August 9, 1993

Manitowoc Engineering Co.
P.O. Box 70
Manitowoc, WI 54221-0070

Dear Sir:

We have been requested by an owner we work for to load test each of our cranes to 110% of their rated capacities.

As you are probably aware: OSHA 1926.550(a)(1) states:

"The employer shall comply with the manufacturer's specifications and limitations applicable to the operation of any and all cranes and derricks."

We read in your operator's manual not to exceed the rated capacity of the crane. I have two questions:

1. Is making a test lift of 110% exceeding the rated limitation capacity of the crane?

2. If it is exceeding the limitations rating of the crane, may we have permission to test lift to 110% of the crane's capacity so we will be in compliance with OSHA 1926.550(a)(1)?

Sincerely,



Al Willis
Safety Director




August 20, 1993

Al Willis
Barnard Construction Co., Inc.
P.O. Box 99
Bozeman, MT 59771-0099

Dear Al:

Subject: Manitowoc Liftcrane Field Test Policy

To certify the integrity of our cranes, Manitowoc Engineering Co. policy, consistent with ANSI B30.5 Code which is adopted by OSHA, is to allow crane user to lift test loads to maximum 10 percent over rated chart capacities.

Machine must be equipped and operated as noted on applicable capacity chart.

Any questions, please call.

Sincerely,

MANITOWOC ENGINEERING CO.



Todd W. Berg
Crane Sales Representative