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Overload limiters used as upper stops on chain hoists

Summary A regional office asked whether a chain hoist's overload limiting clutch could also act as an upper travel stop. OSHA said the cited hoist standards required a top stop and prohibited using the overload limiting device to sense a constrained load; the described hook bottoming against the case was such a load. OSHA now archives this memorandum as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-09-17-0
Date issued
September 17, 1990
Status
Archived by the agency
OSHA archives this memorandum and says it may no longer represent OSHA policy.
Status last verified October 9, 2026

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The current status of this document is unclear
OSHA archives this memorandum and says it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 17, 1990

TO: JOHN MILES REGIONAL ADMINISTRATOR

THROUGH: LEO CAREY, DIRECTOR, OFFICE of FIELD PROGRAMS

FROM: PATRICIA K. CLARK DIRECTOR DESIGNATE, DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Request for National Office Interpretation of ANSI B30.11 as it Relates to Yale KEL 2-ton chain hoists

Your December 1, 1989 memorandum to Leo Carey, Director, Office of Field Programs, has been referred to this office for response. We apologize for the delay.
Your memorandum requests a National Office interpretation regarding the Occupational Safety and Health Administration's (OSHA) position with respect to the applicability of ANSI standard B30.11 to Yale KEL 2-ton chain hoists in which the load limiting clutch also acts as an upper limit travel stop device.
Following is the National Office position on this matter: Section 11-1.10 of ASME/ANSI B30.11-1988 which addresses manual or powered hoists units used as part of a monorail or underhung crane system, shall comply with requirements as stated in ASME/ANSI B30.16-1987 (copy enclosed).
ASME/ANSI B30.16-1987, in its Chapter 16-1 Section 16-1.2.1(f), specifies that electric chain hoists are governed by the requirements of ASME/ANSI HST-1 M-1989 (copy enclosed).
HST-1 M 1989 Section 3.8 requires that electric chain hoists be equipped with a top stop device. The last paragraph of Section 3.9 of HST-1-M1989 requires that the overload limiting device on electric chain hoists "shall not be used to sense the overload imposed by a constrained load".
The use of the overload limiting device as a top stop when the hook bottoms on the case, imposing an overload of 175% is interpreted to be a constrained load and, as such, is forbidden by the standard.
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