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I am glad this discussion came up. I've never found an exact answer or direct interpretation letter for this one. I try to read the letters to infer on how OSHA might approach these ambiguous issues. If you read the interpretation letter on overhead guard removal you will see they allow the guard to be removed in areas it is necessary, but require re-installation in areas where it is not necessary.

CYA approach: I always advise that if you remove the LBR due to stacking in trucks you should keep it on-hand and close for reinstallation in other parts of the warehouse where that tight stacking isn't an issue. I find this a more common question/concern with 83/189 TSU masts, as those with truckers masts usually know the deal. I doubt many companies are actually re-installing the LBR's, but at least the LBRs are on-site and the facility manager prepared for an explaination of the operational plan in the case of an inspection... I feel like this plan would allow immediate compliance.

OHG interpretation letter: w w w.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=18402
  • Posted 9 Feb 2013 00:49
  • By BrassTacks
  • joined 13 Mar'09 - 8 messages
  • Illinois, United States

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