November 8, 1999

Hidden Harbour Marina
4370 Carraway Place
Port of Sanford
Sanford, FL 32771

Dear Mr. Borum:

Thank you for your September 10, 1999 letter to the Occupational Safety and
Health Administration's (OSHA's) Directorate of Compliance Programs (DCP).
You have questions regarding the applicability of §1910.178(l) Powered
Industrial Truck operator training to "Travel Lift" operators. Your specific
questions have been restated below for clarity.

Questions. What is OSHA's actual position on travel lift training for the
December 1999 deadline? What rule applies?

Response. In your letter, you mention that you have an Acme 25-ton Travel
Lift that is used to lift boats from the water for service. You stated that
the travel lift is inspected yearly in accordance with 29 CFR §1910.179 and
the American National Standard Institute (ANSI) B30.2 Overhead and Gantry
Cranes. In addition, you provided manufacturer's information on a Marine
Travelift Inc., Mobile Boat Hoist which you stated was a typical travel
lift.

Based on the information you provided, a "travel lift" which is
manufactured, maintained, operated, and inspected in accordance with ANSI
B30.2 would be considered as a "mobile gantry crane." OSHA's Overhead and
gantry crane standard, §1910.179 would be applicable for this type of
equipment. Therefore, the powered industrial truck operator training
standard with the December 1999 training compliance date would not be
applicable.

However, please be advised that 29 CFR 1910.179(b)(8) requires that only
designated personnel be permitted to operate a crane. OSHA defines
designated at 1910.179(a)(35) as:

Selected or assigned by the employer or the employer's representative as
being qualified to perform specific duties [emphasis added].

Because the term "qualified" is not itself defined, OSHA would interpret
"qualified" in light of operator-qualifications provisions of industry
standards such as ANSI B30.2. Although the 1910.178 training requirements do
not apply, you may also find it useful to consult that standard when
developing a training or evaluation program for "travel lift" operators.

Thank you for your interest in occupational safety and health. We hope you
find this information helpful. Please be aware that OSHA's enforcement
guidance is subject to periodic review and clarification, amplification, or
correction. Such guidance could also be affected by subsequent rulemaking.
In the future, should you wish to verify that the guidance provided herein
remains current, you may 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 Compliance Assistance at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs






"Commodore Joe Redcloud" wrote in message
...
On Fri, 02 Dec 2005 13:52:30 +1100, OzOne wrote:

On Fri, 02 Dec 2005 01:13:48 GMT, Commodore Joe Redcloud
scribbled thusly:

On Thu, 1 Dec 2005 20:15:37 -0500, "Scotty"
wrote:

It isn't?

Scotty


Oi! It's not a crane, potty-scotty. It's called a Travel lift. It does
not fit
the definition of "crane", just like you and gaytex-joe do not fit the
definition of "sailor".


Commodore Joe Redcloud

Well actually it does.
It's covered by the same industrial rules as a crane.


It's technically a hoist, but not a crane. A crane is another type of
hoist.

Cats and dogs have a lot of similarities too, but they are not the same
thing.


Commodore Joe Redcloud