August 28, 2003

Mr. Jerry Gillooly
3805 Old bury Street
Lambertville, MI 48144

Dear Mr. Gillooly:

Thank you for your July 15, 2003 letter to the Occupational Safety and Health Administration (OSHA). In your original letter dated February 18, 2003 to OSHA's Directorate of Enforcement Programs (DEP), you requested an interpretation of 29 CFR 1910.179(j)(3), Overhead and Gantry Cranes, with regard to periodic inspections. Please be advised, 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.

Questions: You inquired as to "What constitutes a complete inspection? The standard does not define either a complete inspection or a periodic inspection."

You asked whether this definition is consistent with OSHA's requirement for a complete inspection, "Or does a complete inspection necessitate disassembly and/or examination methods more advanced or more sensitive than visual? (For example, do gear cases, bearing enclosures, etc. have to be dismantled and each individual component examined? Do they have to be opened for visual examination? Or is an external examination sufficient? "Certainly I understand that the discovery of defects during any inspection requires further, more detailed, examination, but this question relates only to the initial phase of the inspection process."

You indicated the current version of American National Standards Institute/American Society of Mechanical Engineers ANSI/ASME B30.2, defines a periodic inspection as a "Visual inspection of the equipment in place..."

Response: As stated in 29 CFR 1910.179(j)(3), OSHA defines a periodic inspection as, "Complete inspections of the crane shall be performed at intervals as generally defined in paragraph (j)(1)(ii)(b) of this section, depending upon its activity, severity of service, and environment, or as specifically indicated. These inspections shall include the requirements of paragraph (j)(2) of this section and in addition, the following items. Any deficiencies such as [those] listed shall be carefully examined and [a] determination made as to whether they constitute a safety hazard..." Paragraph 1910.179(j)(2) specifies inspection frequencies for potential hazards associated with cranes.

With regard to your specific question concerning gear cases and bearing enclosures, paragraph 1910.179(j)(3) states, "Periodic Inspection ... (see above) ... (iv) Worn cracked or distorted parts such as pins, bearings, shafts, gears, rollers, locking and clamping devices..."

Therefore, as this is a performance standard, it is the responsibility of the employer to assess and determine during frequent and periodic inspections in accordance to the frequencies specified in paragraphs (j)(2) and (j)(1), whether "disassembly and/or more advanced examination methods than visual inspections" are required. If the employer can assure that any defects are detectable through visual inspection, then that would meet the intent of the standard. If not, disassembly of some components may be necessary. For example, under 1910.179(j)(2)(iii), hooks have to be visually inspected daily. However, please note that the "initial phase of the inspection process" you mention would depend on each specific crane and the hazards present (case-by-case-basis). This means that a crane component can malfunction during the operation of the crane, where disassembly may be required, in order to visually inspect and replace the malfunctioning component.

Finally, this interpretation letter is for 29 CFR 1910.179 only and is not intended to interpret ANSI/ASME standards. You may request an official interpretation of the ANSI/ASME standard by directing your request to the Secretariat of the ASME B30 Committee, for the ASME B30.2 Subcommittee. In order to obtain an official ANSI/ASME interpretation on this issue, you may direct your inquiry to:

The American Society of Mechanical Engineers
ASME B30 Committee
Three Park Avenue
New York, NY 10016-5990.

Again, 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 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