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OSHA 1917.47

Winch safety requirements

Subpart C

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.47(a), what must I do when moving winch parts present a 'caught-in' hazard to employees?

Under 1917.47(a), moving winch parts that present a caught‑in hazard must be guarded. Under 1917.47(a) requires physical protection to prevent employees from being drawn into drums, gears, shafts, or other moving components.

  • Typical guards include fixed covers, barrier panels, interlocked guards, or guarding that prevents hand or clothing entanglement.
  • Make sure guards do not create new hazards (e.g., by blocking emergency stops) and are inspected regularly for integrity.

Cited: 1917.47(a).

Under 1917.47(b), how should winch stop controls be arranged and marked?

Under 1917.47(b), winches must have clearly identifiable and readily accessible stop controls. Under 1917.47(b) means emergency or normal stop buttons/levers should be obvious, labeled, and reachable without exposing the operator to the hazard.

  • Use high‑contrast colors or standard emergency colors and permanent labels.
  • Position stops so a person can reach them from normal operating positions and from areas where someone might be pulled in.

Cited: 1917.47(b).

Under 1917.47(c), how must portable winches be secured while in use to prevent accidental shifting?

Under 1917.47(c), portable winches shall be secured against accidental shifting while in use. Under 1917.47(c) requires positive measures so the unit cannot move or tip during operation.

  • Common methods: anchor bolts, cleats or chocks, rated straps or chains to fixed points, or placing on a stable, level surface with outriggers where provided.
  • Inspect the securing method before each use and after any change in load or surface condition.

Cited: 1917.47(c).

Under 1917.47(d), when are limit switches required on portable winches and why?

Under 1917.47(d), portable winches must be fitted with limit switches if employees have access to areas from which it is possible to be drawn into the winch. Under 1917.47(d) requires automatic protection where human presence could allow a person to be pulled into rotating or spooling parts.

  • A limit switch prevents overtravel or continued spooling that could pull an employee into the machine.
  • Evaluate any workspace around the winch for potential employee access and install switches where a caught‑in exposure exists.
  • Combine limit switches with guarding and accessible stop controls for layered protection.

Cited: 1917.47(d).

Under 1917.47(e), what does it mean that the provisions of 1917.45(f)(11) apply to winches?

Under 1917.47(e), winches must comply with the requirements set out in 1917.45(f)(11). Under 1917.47(e) makes the inspection/maintenance/testing provisions found at 1917.45(f)(11) applicable to winches.

  • Practically, that means follow the inspection, testing, and maintenance schedules and procedures required for similar cargo handling gear in 1917.45(f)(11).
  • Keep records and correct defects discovered during inspections before returning a winch to service as required by the cited provision.

Cited: 1917.47(e) and 1917.45(f)(11).

Under 1917.47, are winch hooks required to have safety latches to prevent accidental load disengagement?

Under 1917.47 and related marine terminal provisions, hooks on hoisting gear should be latched or otherwise secured to prevent accidental disengagement where appropriate. OSHA has explained that in marine terminals ‘‘Crane hooks shall be latched or otherwise secured to prevent accidental load disengagement’’ (see 29 CFR 1917.45(e)(2) discussed in the LOI). See the Letter of Interpretation on safety latches for guidance: Safety latches on sling hooks (LOI, 2006).

  • Use latch‑equipped hooks where the application makes it practical, or otherwise use positive means (shackles, bridles) to prevent disengagement.
  • Document when a latch is impractical and provide an alternative positive securing method.

Cited: 1917.47 and Safety latches on sling hooks LOI (2006).

Under 1917.47, what does 'readily accessible' stop control mean in practice?

Under 1917.47(b), 'readily accessible' stop controls means emergency and normal stop controls must be positioned and marked so an employee can reach and operate them quickly from normal working positions without exposing themselves to additional hazards. See 1917.47(b).

  • Place stops within arm's reach of the operator and near areas where someone could be pulled in.
  • Keep controls unobstructed, labeled, and maintained so they function when needed.

Cited: 1917.47(b).

Under 1917.47, can an operator leave winch controls while a load is suspended or a winch is running?

Under 1917.47 and OSHA interpretation of operator responsibilities, an operator must not leave controls while a suspended load or machine operation creates an unsafe condition; leaving controls in that situation can violate safe‑operation requirements. While 1917.47 addresses winch equipment requirements, OSHA has also stated generally that an operator must be physically able to complete assigned tasks and not leave controls when it would affect safety (see OSHA letter on crane operator medical condition). See 1917.47 and the LOI on operator incapacity: Crane operator medical condition (LOI, 2013).

  • Ensure procedures assign a competent operator to remain at controls until the operation is complete or a safe handover is made.
  • If an operator may become incapacitated, provide backup controls, crew assistance, or protective devices (e.g., limit switches, guards) to eliminate the hazard.

Cited: 1917.47 and Crane operator medical condition LOI (2013).

Under 1917.47, if I modify a winch control or add aftermarket devices, do I need the manufacturer's written approval?

Under 1917.47 and related marine terminal requirements, modifications that affect a piece of equipment's capacity or safety generally should not be made without the manufacturer's prior written approval or equivalent engineering approval. OSHA's guidance on modifications to powered industrial trucks and related equipment explains this principle; see the LOI on strobe lights which discusses prior written approval where safety or capacity may be affected. See 1917.47 and the LOI: Strobe lights on industrial trucks (LOI, 2004).

  • Obtain written approval from the manufacturer or a qualified registered professional engineer before making safety‑affecting modifications.
  • After modification, retrain operators if the change affects safe operation.

Cited: 1917.47 and Strobe lights LOI (2004).

Under 1917.47, what should I do if an inspection finds a defect in a winch that could cause a caught‑in or shifting hazard?

Under 1917.47 and the inspection provisions it incorporates, any defect that creates a hazard must be corrected before placing the winch back in service. 1917.47(e) makes the 1917.45(f)(11) inspection/maintenance rules applicable to winches.

  • Tag out and remove the winch from service until repairs are completed by qualified personnel.
  • Record the inspection findings and repairs as required by the applicable inspection provision.

Cited: 1917.47(e) and 1917.45(f)(11).

Under 1917.47, what are common examples of 'moving winch parts' that need guarding to prevent caught‑in hazards?

Under 1917.47(a), moving winch parts that commonly present caught‑in hazards and therefore need guarding include drums, spooling wire rope or cable, open gears, rotating shafts, and drive chains. See 1917.47(a).

  • Exposed wire rope spools: guard to prevent fingers or clothing from being caught during spooling.
  • Gears and couplings: shield or enclose to prevent entanglement.
  • Rotating shafts and sprockets: provide fixed guards or barriers.

Cited: 1917.47(a).