April 25, 2006

Mr. James V. Normand
Hoist and Crane Service Group
915 Distributors Row
Harahan, Louisiana 70123

Dear Mr. Normand:

Thank you for your November 10, 2005 letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry Enforcement regarding an interpretation of 29 CFR 1910.179(h)(2)(iii)(a). You stated that there may be a possible discrepancy with a recent American Society of Mechanical Engineers (ASME) B30 Standards Committee interpretation. The background, scenario, and question have been restated below for clarity.

Background: The American Society of Mechanical Engineers (ASME) B30 Standards Committee stated in a September 26, 2005 interpretation letter the following:

Background: The following statement appears in Para. 2-1.14.3 of ASME B30.2, Para. 11-3.2.3 of ASME B30.11, and Para. 16-1.2.6 of ASME B30.16:

No less than two wraps of rope shall remain on the drum at each anchorage of the hoist(ing) drum when the hook is in its extreme low position unless a lower-limit device is provided, in which case no less than one wrap shall remain.

Question 1: When the hook is in its "extreme low position," does this mean that the hook is at its lowest point of travel when all of the rope has been unwound, except for the required wraps?

Reply 1: Yes.

Question 2: When the hook is in its "extreme low position," does this mean that the hook must be capable of traveling all the way to the ground with no load?

Reply 2: No.

OSHA's interpretation letter dated November 3, 2005 stated:

Although the term "extreme low position" is not specifically defined in 29 CFR 1910.179, nor in its source standard, American National Standard Safety Code for Overhead and Gantry Cranes, ANSI B30.2.0-1967, the extreme low position would be the lowest point that the hook could rest on the ground or floor while maintaining at least two wraps of rope. The requirements in the standard are designed so that sufficient and properly fastened rope remains on the drum and the rope does not slip off the drum.

Question: Would a crane with a lower-limit switch installed, that stops the lower travel with at least two wraps remaining on the drum and the hook does not rest on the ground or floor meet OSHA requirements?

Reply: OSHA would consider a crane with a lower-limit switch that stops the lower travel of the hook with at least one or two wraps remaining and does not rest on the ground or floor as a de minimis violation. OSHA's de minimis enforcement policy is that if an employer complies with the clear intent of a standard but deviates from its particular requirements in a manner that has no direct or immediate relationship to safety or health, then the violation will be considered de minimis. Consequently, no citation would be issued. A lower-limit switch, in addition to the required wraps, would provide protection from over-spooling before the load reaches the floor or ground.

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. In addition, from time to time we update our guidance in response to new information. To keep apprised of such developments, you canconsult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs