January 28, 1992

MEMORANDUM FOR:     R. DAVIS LAYNE
                    REGIONAL ADMINISTRATOR

THROUGH:            LEO CAREY, DIRECTOR 
                    OFFICE OF FIELD PROGRAMS

FROM:               PATRICIA K. CLARK, DIRECTOR 
                    DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:            Use of Cranes to Lift Personnel in Drilled Pier
                    Operations

We have recently addressed this issue in a letter to the International Association of Foundation Drilling. In that letter, we stated OSHA's position as follows: A boatswain chair suspended by reliable hoisting equipment utilizing an A-frame can be used by employees entering drilled pier foundations provided the applicable standards are met including the procedures outlined in 29 CFR 1926.451,1926.452(o) and 1926.651(g)(2)(ii). However, if jobsite conditions prevent the use of A-frame equipment or the use of such equipment would be more hazardous than the use of a crane, a mobile crane can be used for this purpose provided the employees are lowered in a personnel platform in accordance with the requirements of 29 CFR 1926.550(g).

We are aware that a standard personnel platform is often poorly designed to function well in a drilled pier application. However, we believe a platform could readily be designed that would comply with the requirements of 29 CFR 1926.550(g)(4) that would both provide protection for the employee entering the drilled pier and allow the necessary work to be performed.

In regard to whether there have been any variances granted by OSHA for similar activities, please be advised that we have no knowledge of any such variance being issued.