Experience Everything Compliance Network Has to Offer
Start Customizing Your Profile for Free!
Update to Professional Trial!
Already have an account?
YOU'RE ALL SET!
Enjoy your limited-time access to the Compliance Network Professional Trial!
A confirmation welcome email has been sent to your email address from ComplianceNetwork@t.jjkellercompliancenetwork.com. Please check your spam/junk folder if you can't find it in your inbox.
YOU'RE ALL SET!
Thank you for your interest in EnvironmentalHazmat related content.
You've reached your limit of free access, if you'd like more info, please contact us at 800-327-6868.
Copyright 2023 J. J. Keller & Associate, Inc. For re-use options please contact email@example.com or call 800-558-5011.
RegSenseCranes, Lifts, and ScaffoldingEnforcement and Audits - OSHAMaterials Handling and StorageSafety & HealthGeneral Industry SafetySlings for Materials HandlingOccupational Safety and Health Administration (OSHA), DOLCompliance DocsStandard InterpretationEnglishFocus AreaUSA
Comments on Variance Application Number 2293.
|MEMORANDUM FOR:|| STEVE MALLINGER|
Directorate of Technical Support
|FROM:|| JOHN MILES|
Directorate of Compliance
|SUBJECT:|| Comments on Variance Application Number 2293: VARIANCE|
REQUEST FROM 1910.179(n)(3)(vi), 1910.180(h)(3)(vi),
This memorandum is in response to your request for assistance in evaluating a variance request for Lockheed Martin Astro Space.
Practices that the employer wishes to implement do not provide the same degree of protection as does compliance with the referenced OSHA standards. Therefore, the application should be denied. However, Lockheed Martin should be advised that if they can demonstrate that it is truly infeasible to perform the lifting task, without having employees under the load, the Office Of General Industry Compliance Assistance (GICA) will work with them to develop work practices which will reduce the potential for injury as much as is feasible. The proposals contained in the variance application will be a good starting point in the development of such practices.
The variance application proposes that employees be under suspended loads under certain specific conditions. The applicable OSHA standards require that employees be kept clear of suspended loads, or that the employer shall require that the operator avoid carrying loads over people.
Paragraph (a)(4) of 29 CFR 1905.11 contains the requirement relevant to the preceding comments. It requires that the applicant provide:
"A statement showing how the conditions, practices, means, methods, operations, or processes used or proposed to be used would provide employment and places of employment to employees which are as safe and healthful as those required by the standard from which a variance is sought."
Also, please note that if a sling is used in the lifting of the spacecraft, paragraph (c)(9) of 29 CFR 1910.184 is also applicable to the lifting operation. (A sling is defined as being an assembly which connects the load to the material handling equipment.) That paragraph requires that employees be kept clear of suspended loads. If a sling is used the requirements of 29 CFR 1910.184 should also be considered when making the determination concerning the alternative practices the employer wants to implement.
READ MORESHOW LESS
['Enforcement and Audits - OSHA', 'Materials Handling and Storage', 'Cranes, Lifts, and Scaffolding']
['Slings for Materials Handling']
J. J. Keller is the trusted source for DOT / Transportation, OSHA / Workplace Safety, Human Resources, Construction Safety and Hazmat / Hazardous Materials regulation compliance products and services. J. J. Keller helps you increase safety awareness, reduce risk, follow best practices, improve safety training, and stay current with changing regulations.