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Standard Number: 1910.265
January 7, 1975
MEMORANDUM FOR: JAMES W. LAKE ASSISTANT REGIONAL DIRECTOR/OSH
Subject: Log Handling Machines, 29 CFR 1910.265(d)(1)(ii)(b)
This confirms your telephone conversation with Mr. John B. Lewis, Office of Compliance Programming, on January 3, 1975, regarding your memo dated October 21, 1974, subject: Variance Application and Interim Order Request by Western Wood Products Association (Federal Register, Volume 38, No. 163, August 23, 1973), and your letter dated October 25, 1974, subject: Log Handling Machines Standards 1910.265(d)(1)(ii)(b).
In reviewing the specific standard and the contents of your memo dated October 21, 1974, the following interpretation is provided.
The installation of restrictors complies with the intent of 29 CFR 1910.265(d)(1)(ii)(b) which is to prevent uncontrolled lowering of the load on forks in the case of a failure in the hydraulic system.
Barry J. White Associate Assistant Secretary for Regional Programs
Date: October 21, 1974
Reply to: JWL/mah
Attn of:
Subject: Variance Application and Interim Order Request by Western Wood Products Association (F.R. Vol. 38, No. 163, 8/23/73)
To: Alexander Reis
Thru: Barry White
On February 22, 1974, we transmitted to the National Office a report on field conditions, and video tapes of a subsequent meeting with employers' and manufactures' representatives to assist you in resolving the subject variance application which is concerned with hydraulically operated log handling machines.
I prepare this memorandum in respect to the attached correspondence from the representative union. You will notice that they are concerned with the National Office's handling of the variance application and its ramiform effects. I too am concerned because a study of the variance application file indicates that the National Office has surrounded the variance application with a cloud of confusion and has now dragged its feet for two and one half years without resolving the problem
Our report of February 22, 1974, made three recommendations and I direct your attention to Recommendation No. 1 which reads as follows:
A 100-Series interpretation is necessary to extricate all parties involved with, or affected by, Standard 1910.265(d)(1)(ii)(b). This interpretation should define a "positive device for preventing an uncontrolled lowering of the load or forks" as a device which will positively prevent the load or forks from lowering at a speed greater than 10 cm/sec in case of a failure in the hydraulic system.
There is no doubt in my mind that the eventuation of the above recommendation would resolve the problem to the satisfaction of all concerned parties. Some manufacturers have equipped their machines with such restrictors for several years. The Caterpillar Company informs us that at least one European importing country requires them to install restrictors to comply with their safety standards.
Your intention, to amend Standard 1910.265(d)(1)(ii)(b) so that it will apply to the boom lifting cylinders of hydraulically operated crane type log handling machines in which the load is lifted by wire rope, baffles me. We have contacted the States of Oregon and Washington and one equipment dealer to acquire information on the machine involved in the future proposed amendment. None of them is aware of the use of such a machine in log handling, and I wonder where the ANSI Committee acquired its information.
Also, in the aforementioned report and video tapes, I direct your attention to the discussion on load lock valves for the "tusks" or load clams. All concerned parties agree that the load lock valves are more important here than on the load cylinders especially because more employees are exposed over a wide area. These log handling machines have a capacity of up to 120,000 pounds. In the event of a failure in the hydraulic system, an elevated load of logs would cascade over a large area crushing workers in their paths. I have not seen any action on our initial OSHA 9 to cover this situation. I have, therefore, attached a new one. Also attached are a couple of clippings which illustrate these machines.
James W. Lake
Assistant Regional Director
Enclosures
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