July 8, 2011

Mr. Clint Bridges
EZ Scaffold
810 Mayberry Springs Road
Columbia, TN 38401

Re: Applicability of OSHA's Cranes and Derricks standard to hoists attached to mast climbing platforms

Mr. Bridges:

This letter addresses your inquiry dated December 10, 2010 via email to Mr. Parsons of the Occupational Safety and Health Administration (OSHA). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not detailed within your original correspondence.

In your inquiry, you requested guidance on OSHA's requirements for the use of hoists mounted on mast climbing scaffolds. Your email contained graphics and a photograph of the hoist system EZ Scaffold uses, which is an underhung hoist mounted on a monorail that has been secured to the scaffolds platform so that the hoist is above the platform. This type of hoist appears to be used to deliver materials to workers standing on the scaffold by rolling the hoist horizontally out towards the end of the monorail, retracting the hoist line to lift the load vertically, and then moving the hoist horizontally along the monorail back over the scaffold platform. The extension and retraction of the hoist line is typically accomplished through power-operated equipment, and OSHA assumes that the vertical lifting is power-driven. The request does not indicate, however, whether powered equipment causes the horizontal movement of the hoist along the monorail, or whether the hoist is moved vertically by hand.

We have paraphrased your question as follows:

Question (1): Does the new cranes and derricks standard apply to the hoists on mast climbing platforms described in your request?

Answer: The scope of the new Cranes and Derricks in Construction standard, 29 CFR 1926.1400(a), is limited to "power-operated equipment, when used in construction, that can hoist, lower, and horizontally move a suspended load." The hoist mechanism described in your request is attached to a monorail, can lift a suspended load vertically up from the ground to the scaffold and horizontally along the monorail. OSHA specifically notes in the new standard that "a crane on a monorail" is included within the scope of the new standard. See 1926.1400(a). Therefore, the equipment you describe is covered by the new cranes and derricks in construction standard to the extent it is "powered-equipment used in construction."

OSHA did not define "power-operated equipment" in the cranes standard. In the context of 1926.1400(a), OSHA interprets the phrase as applicable to both the horizontal and vertical movements of the load. Therefore, if the hoist uses powered-equipment to move the load horizontally along the monorail, the hoist in your request is covered by the new crane standard. If the only horizontal movement of the hoist is by hand, without the assistance of any motor or other powered-equipment, the hoist would not constitute powered-equipment under 1926.1400(a), and the equipment would be subject to 29 CFR 1926.552, Material hoists, personnel hoists, and elevators, rather than the new cranes standard. In addition, please note that only the requirements of 29 CFR 1926.1441, which does not include, for example, operator certification requirements, apply to equipment with a capacity of 2000 lbs or less.

Question (2): Does the new crane standard still apply to hoists on a mast climbing platform if the load is suspended by a means other than a hook?

Answer: Yes. The answer provided to Question (1) is valid regardless of whether a hook or a shackle is used.

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 further questions, please feel free to contact the Directorate of Construction at (202)693-2020.

Sincerely,


James G. Maddux, Director
Directorate of Construction