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.

October 6, 2004

Mr. Bob Nutt
PACE Health & Safety Representative
BP Products North America Inc.
Toledo Refinery
P.O.Box 696
Toledo, OH 43697

Dear Mr. Nutt:

Thank you for your inquiry dated March 23, 2004 regarding the Occupational Safety and Health Administration's (OSHA) rule at 29 CFR 1910.179, Overhead and Gantry Cranes. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. We apologize for the delay in our response. Your paraphrased question and our response are provided below.

Question: The language in §1910.179(n)(2)(ii) states: "The load shall be attached to the load block hook by means of slings or other approved devices." Is it permissible to attach the load above the block hook to the running rope (cable) itself?

Response: No. The quoted provision requires the load to be attached to the hook (by means of a sling or other approved device). In addition, attaching the load above the block hook to the running rope itself could result in violation of §1910.179(n)(2)(i), which states: "The hoist chain or hoist rope shall be free from kinks or twists and shall not be wrapped around the load."

Thank you for your interest in occupational safety and health. 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 further 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