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Older manlifts and later design standards

Summary A parking operator asked OSHA to grandfather two manlifts installed in 1956 and 1964. OSHA said the cited design requirement applied to equipment installed after its 1971 effective date, so those lifts were outside that requirement, though the employer still had to protect workers from recognized hazards.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-12-05
Date issued
December 5, 1991
Status
Active
Status last verified October 9, 2026

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December 5, 1991
Mr. William P. Mitchell
Operations Manager
Diversified Parking, Inc.
[Recipient address omitted]

Dear Mr. Mitchell:
This is in response to your letter dated November 6, in which you request that we "grandfather" two manlifts.

As you stated in your letter, the standard states that "all new manlift installations and equipment installed after the effective date of the regulation shall meet the design requirements of the American National Safety Standard'...". Since the manlifts you ask about were installed in 1956 and 1964 and the effective date of the regulations is August 1971, you are not bound by the requirements of the standard. However, you are still required to provide a work environment and working conditions that are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.

No further action is needed or will be taken on your request for "grandfathering." Nevertheless, should you require further information or assistance, you may contact:

Edward J. Cosgrove, Area Director
US Department of Labor - OSHA
1205 Texas Avenue
Room 421
Lubbock, Texas 79401
806-743-7681

I hope that the information provided will be of help to you.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

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