Transcript Presentation Title

Crane Questions
Jim Shelton, HNAO CAS
These are not necessarily official
OSHA opinions but guidance until
official interpretations may or may not
be issued.
Question 1
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What is ‘Construction’ work?
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OSHA 1910.12(b) – “work for construction,
alteration, and/or repair, including painting or
decorating”
The Commission looks at that where work is
an integral part of a larger project that
involves the ‘replacing’ and/or ‘altering’ of
existing equipment or property the work is
construction
Construction is all types of work integral to
the overall project
Question 1
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Davis Bacon Act 29 CFR 5.2(j) work
done by laborers and mechanics
employed by a construction contractor or
subcontractor
(i) Altering, remodeling, installation (where
appropriate) on the site of the work of items
fabricated off-site
(ii) Painting and decorating
(iii) Manufacturing or furnishing of materials, articles,
supplies or equipment on the site of the building
or work
Question 2
• 1427(b)(1)(ii)(B) Provide different levels of
certification based on capacity and type…
How does that related to certification in
regards to crane tonnage?
– Under discussion with stakeholders.
Considering ranges of tonnage which
operators could be certified such as up to
20T, 20T-150T, 150T-500T, 500T+
Question 3
• Question - We use a device like ‘A’, no boom or winch
but uses hook under the forks of the JLG Telehandler.
Does it still qualify as a P.I.T.?
• DOC Says – ‘A’ would be exempt, ‘B’ would be included.
New rotating cab telehandlers may need formal
interpretation
Question 4
• Specifically, is OSHA saying that if an
operator is going to operate a certain type
of crane with a certain capacity, the
operator must be certified on that specific
type and capacity of crane?
– OSHA Fact Sheet on Operator Certification.
“Each accredited testing organization
develops its own categories for crane type
and capacity.” Working to remedy….
Question 5
• Some responsibility for some requirements
are shared by the controlling entity and the
entity operating the crane. How will that
be practically managed at a job site?
– Typically in the standard we have said that a
controlling contractor responsibility will fall to
the crane operator / employer if no controlling
employer is available.
Question 6
• How will we verify that an operator's
training is appropriate? Will only NCCCO
and CCER cards be acceptable?
– Training will be verified in the same ways it is
for anything else, if the operator has a
certification card for the correct type of
equipment but is not operating the equipment
properly he may need to be re-trained. We
understanding certification bodies will have a
data base we could use to verify cards
Question 6
– …There are currently 5 certification bodies,
NCCCO, NCCER, Southern California Crane
& Hoisting Association is now OECP
(Operating Engineers Certification Program),
Crane Institute Certification and Union Pacific
Railroad
Question 7
• What about situations where fall protection
on a crane is required per OSHA, but the
crane equipment has no suitable
anchorage points?
– The standard in 1423(g)(2) says “Personal fall
arrest systems must be anchored to any
apparently substantial part of the equipment
unless a competent person, from visual
inspection, without an engineering analysis,
would conclude that the criteria in
1926.502(d)(15) would not be met.
Question 8
• Regarding the qualifications for
Assembly/Disassembly Director - what
would a template look like? How much
equipment experience, supervisory
experience, etc.
– Combine the definitions of competent & qualified
persons. The A/D Director must meet both or be
two people. The criteria is the same as for any
QP or CP this is just the first time we have said it
could be one person.
Question 9
• Regarding required annual crane
inspections, specifically for rented cranes,
which entity is responsible for initiating the
inspection - employer owning the crane or
employer using the crane?
– The standard allows any employer to conduct
the monthly inspection. The employer who
conducts the inspection must document the
items checked
Question 9
– …checked and the results of the inspection
and must retain it for a minimum of three
months. If employers whose employees use
the equipment rely on another employer to
conduct, document, and maintain the record
of the monthly inspection, it is the
responsibility of each employer engaged in
construction activities to assure compliance
with the standard.
Question 9
– that it is in the interest of all employers who
conduct monthly inspections, whether they
use or own equipment, to share the inspection
results with each employer who uses the
equipment. However, employers engaged in
construction activities are responsible for
assuring compliance with the standard.
Therefore, if an employer engaged in
construction activities is unable to assure that
Question 9
– … another employer has conducted the
monthly inspection, then the employer
engaged in construction activities must
conduct a monthly inspection prior to using
the equipment
Question 10
• Do all riggers and signal persons need to
be qualified by November 8 or will there be
a grace period to allow time for training?
– Rigger and signal persons are to be qualified
by November 8th.
– Signal persons must have their qualifications
“certified” by a qualified evaluator.
– The employer must ensure the rigger is
“qualified” by November 8th, 2010.
Question 11
• How does a qualified evaluator qualify a
rigger? Can the evaluator simply attest to
the experience of the employee or is a
written test and/or hands-on evaluation
required?
– Per 1926.1428, a qualified evaluator must
ensure that a signal person meets the
qualification requirements listed in 1428(c).
There is no requirement for a qualified
evaluator to qualify a rigger.
Question 11
– …The employer is responsible for ensuring
the rigger is qualified for the work he is to
perform. 1926.1401 defines a ‘‘qualified
rigger’’ as a rigger who meets the criteria for a
qualified person. Simply, the rigger must be
qualified for the work being done at the
moment. There is no expectation for a rigger
to be qualified in ALL things rigging, only
qualified for exactly what is being done now.
Question 12
• Considering the definition of a qualified
person, would a training class that
includes a written and hands-on evaluation
be considered “extensive knowledge,
training, and experience” to deem an
employee a qualified a signal person or
rigger?
– . It would not be appropriate to generally say
a written and hands-on evaluation
Question 12
– …would be considered adequate because
you don’t know the content of the evaluation.
The means and methods used to “qualify” a
signal person are not specified in the
standard. Any means or method would be
acceptable as long as the signal person can
demonstrate to the satisfaction of a qualified
evaluator that they meet the requirements of
1428(c).
Question 12
– …in regard to the qualified rigger it is
important to understand a one size fits all
approach will not work. If a rigger is picking
things with one ½” choker and moving them
50 foot around a dirt lot is way different than a
rigger making a heavy complex lift over an
obstacle of great hazard like a tank of
ammonia. One may be qualified to use a
single choker but no where near qualified to
use ten chokers and a couple chain falls all in
the same complicated engineered pick.
Disclaimer
•
This information has been developed by an OSHA Compliance Assistance
Specialist and is intended to assist employers, workers, and others as they
strive to improve workplace health and safety. While we attempt to
thoroughly address specific topics [or hazards], it is not possible to include
discussion of everything necessary to ensure a healthy and safe working
environment in a presentation of this nature. Thus, this information must be
understood as a tool for addressing workplace hazards, rather than an
exhaustive statement of an employer’s legal obligations, which are defined
by statute, regulations, and standards. Likewise, to the extent that this
information references practices or procedures that may enhance health or
safety, but which are not required by a statute, regulation, or standard, it
cannot, and does not, create additional legal obligations. Finally, over time,
OSHA may modify rules and interpretations in light of new technology,
information, or circumstances; to keep apprised of such developments, or to
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you can visit OSHA’s website at www.osha.gov.