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Standards for coal barge unloading equipment

Summary A testing laboratory asked which OSHA standards applied to a crane-supported coal unloader used at a power plant's barges. OSHA said the equipment fell under its longshoring standards, including the then-cited certification rule for shore-based material-handling devices. OSHA now archives the letter and warns that it may no longer represent agency policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-01-16-0
Date issued
January 16, 1991
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.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OSHA archives this letter and says it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 16, 1991

Lee Hand Quad City
Testing Laboratory, Inc.
[Recipient address omitted]
Dear Lee:

This correspondence is in response to your letter dated August 30, 1990, and confirms your conversation with Mr. Steve Butler of my staff on January 16, 1991. Please excuse our delay in providing written response.

You have requested clarification concerning the applicable standards which apply on barge loading equipment. As detailed by you the equipment in question is used for unloading coal from barges at a power plant on the Mississippi River, is operated by employees of the power company, and consists of a bulk cargo sucker supported by three cranes.

This barge loading equipment would be covered by maritime standards for the longshoring industry, 29 CFR 1918. Further, this equipment would have to meet the requirements of 1918.13 "Certification of shore-based material handling devices", paragraph (d).

Our current address remains:

Department of Labor - OSHA
Office of Construction and
Maritime Compliance Assistance
200 Constitution Avenue, N.W. Room N3610 Washington, D.C. 20210
Attn: Gerald P. Reidy

Feel free to write us at the above address or contact us by phone at (202) 523-8131, should you require further clarification or have additional questions.

Sincerely,
Gerald P. Reidy, Director
Office of Construction
and Maritime Compliance Assistance

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