June 1, 1994

Mr. George M. Tomer, Manager
Occupational Safety and Health
Lockheed Missiles & Space Company, Inc.
1111 Lockheed Way
Sunnyvale, California 94089-3504

Dear Mr. Tomer:

The purpose of this letter is to respond to your correspondence of March 23, concerning ballast can operations on submarines. We have reviewed your proposed method of hoisting and lowering employees in a boatswain chair by means of a davit arm dedicated to personnel hoisting. In addition to providing a means to rescue disabled employees, the davit arm system appears to be a safe, feasible means of hoisting employees. Consequently, use of the davit arm system as described in your letter would be considered as an acceptable means of complying with the intent of 29 CFR 1915.116(i) which prohibits employees from riding the load. Naturally, the proposed system must comply with all other OSHA regulations regarding the hoisting of personnel.

We appreciate your continued interest in safety and health matters.

Sincerely,



Roy F. Gurnham, P.E., J.D.
Director
Office of construction and
Maritime Compliance Assistance