thank you joseph, i really appreciate your response. i interpreted the rule the same way but it is a little vague about "improvements" that do not actually change the capacity or safety systems ie: original bolts in place on an lbr and additionally a weld performed by a certified welder, the only sticking point is that the customer made these mod's. we occaisonally do this as part of the make ready when requested but we are a dealer. this situation has come up very recently and osha cited the customer. it's being appealed. (they love that) what's your personal opinion on this subject?