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Crane-supported overhang form as a scaffold or personnel platform

Summary A form-system maker asked which OSHA rules applied to a crane-supported access platform. OSHA said that, if the hoist was secured and the platform stayed still with workers on it, it would be treated as a suspended scaffold; if moved with workers aboard, crane-suspended personnel-platform rules applied. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-04-19
Date issued
April 19, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent current policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 19, 1994

Mr. Clark W. Thompson, P.E.
Vice President
United Form Services, Inc.
[Recipient address omitted]
Dear Mr. Thompson:

This is in response to your July 2 letter requesting a compliance determination from the Occupational Safety and Health Administration (OSHA) regarding your "Girder Lock Overhang Form System." I apologize for the delay in responding to your inquiry.

We have reviewed the product information that you provided and have determined that if the C-Caddy is used as described in your letter, OSHA would consider it a suspended scaffold and the requirements in 1926 Subpart L (1926.451) would apply. This determination is contingent upon the crane hoist drum being dogged off and the C-Caddy being stationary at all times while employees are on the platform. A safe means of access and egress is required to and from the C-Caddy and as stated in your letter, all persons must be tied-off while on the platform.

Please note that if the C-Caddy is moved while employees are on it, OSHA would consider it a crane suspended personnel platform and the requirements contained in 1926.550(g) would apply.

If you wish to apply for a formal variance from one or more of these standards, please refer to 29 CFR 1905 and contact OSHA's Office of Variance Determination in the Directorate of Technical Support at (202) 219-7193.

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,

Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]

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