March 6, 1989

MEMORANDUM FOR:     JAMES W. LAKE
                   Regional Administrator, Region X

THRU:               LEO CAREY, Director
                   Office of Field Programs

THRU:               THOMAS J. SHEPICH, Director
                   Directorate of Compliance Programs

FROM:               GERALD P. REIDY, Director
                   Office of Construction and Maritime
                     Compliance Assistance

SUBJECT:            Interpretation re:  "Billy Pugh" basket

As you are aware, there are no regulations in the OSHA maritime or general industry standards that address transferring personnel from an oil platform to and from a boat.

As far as the Construction Standards are concerned, the "Billy Pugh" basket does not meet the requirements of 29 CFR 1926.550(g)(4), "Crane or Derrick suspended Personnel Platforms". Specifically, the basket does not meet the requirements of sections 1926.550(g)(4)(i)(b), (4)(ii)(a), (4)(ii)(b), (4)(ii)(e), (4)(ii)(f), (4)(ii)(i) and (4)(iv)(a). It is also felt that this basket could not be brought into compliance with this construction standard.

We would suggest that if the basket is used to transfer personnel, that a safety belt be used to provide a more positive means of preventing a person from falling from the basket, particularly in rough weather, and tag lines be attached to the basket to help guide it to its destination.