Riding vertical reciprocating conveyors

July 30, 1984

Mr. Andrew Cicillini
Chief Elevator Inspector
Department of Labor
[Recipient address omitted]
Dear Mr. Cicillini:

This is in response to your letter of July 10, 1984, concerning vertical reciprocating conveyors.

The Occupational Safety and Health Administration (OSHA) regulates the use of vertical reciprocating conveyors used in general industry under various standards relative to specific types of applications. These regulations can be found at 29 CFR 1910.107(b)(7), .107(h)(7), .108(c)(6), .218(j)(3), .263(d)(7), .263(i)(7), and .265(c)(18). All other applications of conveyors are regulated under 29 CFR 1910.212, general requirements for all machines. In this regard, OSHA relies on the recommendations of the ANSI B20.1-1976 for the acceptable safeguarding of employees exposed to conveyors.

ANSI B20.1-1976, sections 5.12.4 and 6.21.1.3 prohibit the riding of vertical and vertical reciprocating conveyors. As a result of these recommendations, OSHA does not permit the riding of such conveyors by personnel. Therefore, since these conveyors are not intended for the transport of personnel, they are not properly within the scope or application of the elevator standards set forth by ANSI A17.1.

OSHA considers the riding of vertical reciprocating conveyors by employees to be in violation of 29 CFR 1910.212(a)(1) in that, the safety of personnel cannot be assured. However, should such an installation also meet the criteria of ANSI A17.1, OSHA would reevaluate this position relative to such specific installations.

I hope this information is useful to you and your panel. If we may be of further assistance, please contact us.

Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

[Requester letter reproduced on OSHA page; omitted here.]