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Boom-mounted work platforms and aerial lift rules

Summary A refinery association asked which construction standard applied to a work platform fixed directly to a crane boom. OSHA said the modification made the crane a personnel carrier subject to aerial lift requirements, including applicable ANSI rules and dual controls. OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-05-23-4
Date issued
May 23, 1989
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy; the posted page notes a correction on June 2, 2005.
Status last verified October 10, 2026

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The current status of this document is unclear
OSHA archives this letter and says it may no longer represent OSHA policy; the posted page notes a correction on June 2, 2005. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 23, 1989
Karl Brendal, P.E.
National Cooperative Refinery Association
[Recipient address omitted]
Dear Mr. Brendal
This is in response to your correspondence and subsequent phone conversations with members of my staff, concerning which standard(s) would apply to a personnel platform attached directly to a boom.
Your statement concerning the applicability of [29 CFR 1926.550(g)] and [1926.453] is correct; primarily because adding a work platform attached directly to the end of a boom changes the use of the crane to a personnel carrier. Therefore, all requirements of aerial lifts would apply. Also this change would be a modification after the effective date of the standard and the unit would be required to meet the applicable requirements of the American National Standards Institute for "Vehicle Mounted Elevating and Rotating Work Platforms," ANSI A92.2-1969. You are also correct in requiring for dual controls which are addressed in [29 CFR 1926.453].
We appreciate your interest in safety and health matters and in promoting the safe application of hoisting equipment. We also appreciate your desire to comply with all applicable standards. If we can provide additional information, feel free to contact our office.
Sincerely,
Gerald P. Reidy, Director
[Directorate of Construction]
[Corrected 6/2/2005]

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