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Crane-hoisted boatswain chairs in drilled foundations

Summary A foundation drilling association questioned applying general construction rules to drilled shaft entry and crane-hoisted boatswain chairs. OSHA said those operations posed excavation, confined-space, and personnel-transport hazards, and the then-current crane personnel-hoisting rule applied unless a sufficient justification for an exception was provided. OSHA archives the letter and warns that it may no longer reflect current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1992-05-11-0
Date issued
May 11, 1992
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 11, 1992

Mr. Scot Litke
Executive Director
The International Association of
Foundation Drilling
[Recipient address omitted]
Dear Mr. Litke:

This is in response to your March 20 letter and resolution concerning the Occupational Safety and Health Administration's (OSHA) standards addressing mobile crane-hoisted boatswain chairs. I apologize for the delay in responding to you.

As you point out in your letter, OSHA does not have all inclusive standards specific to drilled shaft entry and therefore has applied more general standards to address the hazards associated with drilled foundation activities. Although you have stated that you believe your operations are inappropriately being viewed as falling under diverse regulations, there are in fact, confined space, excavation, personnel transportation, and other concerns when entering drilled foundation shafts. OSHA's past practice has been to promulgate general safety and health standards that apply to all construction operations (e.g., hard hat requirements). When OSHA does promulgate operation-specific standards, it addresses hazards unique to that operation. while we recognize that your type of operations are somewhat unique, the Agency believes that existing standards adequately address the hazards associated with them. Until OSHA promulgates a specific standard (not presently being considered), OSHA must rely on other standards addressing the hazards inherent to those operations.

OSHA's regulations concerning the use of cranes for lifting personnel are relatively new, having been published in August, 1988,. During this rulemaking, the International Association of Foundation Drilling (ADSC) did not submit comments so the Agency is not aware of the specific reasons that a personnel platform cannot be designed for this use, is not feasible, or if the use of a personnel platform would create greater hazards. While the Agency is aware that cranes have been traditionally used to hoist and suspend personnel in boatswain chairs in the drilled foundation industry, these operations, as well as all employers, are bound by the requirements of section 1926.550(g) unless sufficient justification as explained above is provided.

Please be assured that OSHA will be happy to provide as much assistance as possible to the ADSC "Task Force" in their effort in developing industry procedures and practices. If additional assistance is desired, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance. Their telephone number is (202) 523-8136.

Sincerely,

Dorothy L. Strunk
Acting Assistant Secretary

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