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Maintenance as normal crane operating conditions

Summary An OSHA official asked whether occasional maintenance on a crane bridge footwalk counted as exposure during 'normal operating conditions.' OSHA said it did, and planned a directive defining the phrase for crane standards. OSHA archives the memo.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1977-09-27-0
Date issued
September 27, 1977
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Cranes Maintenance Working Platforms
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 27, 1977

MEMORANDUM FOR: DONALD E. MACKENZIE
Field Coordinator

FROM: RICHARD P. WILSON
Deputy Director, Federal Compliance and State Programs

SUBJECT: Standard Clarification Request of 29 CFR 1910.179(e)(6)(i) and (g)(2)(i)

This is in response to the memorandum to: Office of the Field Coordinator Bill Demery, Acting Director NEP; From: W. Gary Adams, Acting Director, NEPCC; dated July 15, 1977; same subject. Mr. Adams requests an interpretation of the term "normal operating conditions" as used in 29 CFR 1910.179(e)(6)(i) and (g)(2)(i) Overhead and Gantry Cranes.
Specifically, Mr. Adams asks "if the only exposed employees in these cases are maintenance men who do occasional maintenance on the crane bridge foot-walk is this exposure during normal operating conditions ---?".
The answer to this question is in the affirmative. OSHA's position is that "normal operating conditions" include maintenance activity.
This office, in the near future, will issue a program directive defining the term as used in the cranes and derricks standards.

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