Customized Spreader Bar Install The Bundle
Customized Spreader Bar Update Our Guidance
Customized Spreader Bar Generator Tube Bundle

At the end of the frame life cycle it has a life separate and apart from the bundle as well.

Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations.

This letter constitutes OSHAs interpretation of the requirements discussed.

Note that our enforcement guidance may be affected by changes to OSHA rules.

Customized Spreader Bar Update Our Guidance

Also, from time to time we update our guidance in response to new information.

To keep apprised of such developments, you can consult OSHAs website at.

In your letter and subsequent conversations with us, you have asked that we clarify how 29 CFR 1926.251(a)(4) applies to Vogt-NEMs spreader frame, strong back frame, shipping frame (ladder frame) and other lifting accessories depicted in the materials you submitted.

Since the sense we have of your inquiries is that they pertain to using these frames and other lifting accessories in the construction of power generation facilities, we have addressed your questions with respect to the obligations of an employer engaged in the construction of such power generation facilities with respect to 29 CFR 1926.251(a)(4).

We are not addressing issues regarding contractual relationships with the owner, with the actual constructor or with the projects various other contractors.

This is the case irrespective of who supplies the devices to the construction employer (we have listed the affected pieces of lifting equipment below).

In your letter you describe the design and use of various Vogt-NEM, Inc.

Customized Spreader Bar Generator Tube Bundle

You use this equipment first as part of the process for manufacturing the generator tube bundle.

Customized Spreader Bar Install The Bundle

It is then used to ship, store, handle, move, and erectinstall the bundle.

All of the equipment that you have asked about function at some time as equipment designed to lift the bundle, and thus are lifting equipment lifting accessories (rigging equipment for material handling).

We have identified the equipment or assemblies used in your construction activities under discussion as including those listed below and any others used in those activities, which fall under the requirements of 29 CFR 1926.251(a)(4).

In addition your procedures include complete inspections, repairs or replacements.

CFR 1926.251(a)(4) states: Special custom design grabs, hooks, clamps, or other lifting accessories, for such units as modular panels.and similar materials, shall be marked emphasis added to indicate safe working loads and shall be proof-tested emphasis added prior to use to 125 percent of their rated load.

This provision does not permit calculations to be used in place of proof testing.

The language is unambiguous Special design.lifting accessories.shall be marked to indicate safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.

Since all the equipment listed above, including your frames and assemblies are custom designs and are used to lift units such as modules or prefabricated structures, they fall within the devices regulated by 1926.251(a)(4).

Although the shipping frame changes uses as it goes through its life cycle, it is used as a custom design lifting accessory at least twice in that cycle and, as discussed during the May 3 rd conference call, usually many more times.

At the very least the shipping frame is used to lift and move its tube bundle in the bundle manufacturing process and during the installation process at the power generator.

This accessory is used as a custom-design lifting accessory at several intermediary stages along the tube bundles journey from creation to power generator construction activity and final installation.

Additionally, the shipping frame falls short of being an integral part of the product it surrounds.

It has a short separate life both at its creation and after tube bundle installation.

Your manufacturing process (as we understand it) creates part of the shipping frame separate from and before the bundles manufacture.

Then the remainder of the shipping frame is tailored around the tube bundle as it is built.