Posted with the kind permission of Ray Feidt -Stephenson Equipment
Well, we have had several months to try to discern the new Fed. OSHA 1926.1400 construction crane regulation. As you have probably figured out, there is a lot there and it is not easy to follow.
This regulation has incorporated by reference many other standards, ASME B30.5 (2004) being one of them. This basically means, OSHA looks at the
incorporated by reference documents as law. So, whenever you are trying to discern what the rules really are, you must reference these other standards also. The full list of incorporated by reference documents are listed in 1926.6.
I am going to try to give an overview of the inspection portion of the regulation, 1925.1412. First, who is qualified to do crane inspections? OSHA
breaks down the qualification into two categories, “Competent Person” and “Qualified Person”. Competent Person - means one who is capable of
identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and
who has authorization to take prompt corrective measures to eliminate them.
Qualified Person - means a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, successfully demonstrated the ability to solve/resolve problems relating to the subject matter, the work, or the project.
Whew, so who is competent and who is qualified. Everything OSHA does is performance driven. Basically, they give you a definition and the employer is
given the task of determining whether a specific person is competent or qualified to perform a specific task. A person that is qualified to do one thing is not necessarily qualified in something else.
When does a crane need to be inspected and by whom?
1. Modified Cranes……any time there is a modification done to a crane, the modification must be inspected by a qualified person.
a. 1926.1434 - Modifications or additions which affect the capacity of a crane or safe operation of the crane are not permitted except …….
i. Where the manufacturer reviews and approves the modification in writing and provides updated load charts, manuals, procedures, or labels as required to comply with the approved modification.
ii. If the manufacturer refuses or fails to review the modification request within 30 days, a registered PE who is a qualified person with respect to the crane and modification involved:
1. Approves the modifications and specifies the configurations that the modification applies to.
2. Modifies load charts, manual, procedures, or labels as required to comply with the approved modification.
iii. The original safety factor of the crane is not reduced.
2. Repaired/Adjusted Cranes…….any time a crane has had a repair to a component that relates to safe operation, it must be inspected by a qualified person prior to initial use.
3. Post Assembly…….after completion of assembly of a crane (tower crane must have a pre-assembly inspection also); the crane must be inspected by a qualified person.
4. Shift inspection. OSHA no longer has a daily inspection; they now call it a shift inspection. It must done by a competent person. This inspection is not required to be documented.
5. Monthly Inspection…….the monthly inspection is simply a documented shift inspection done by a competent person. The employer is responsible to maintain the last three monthly inspections and they must be made available to anyone doing an inspection on the crane.
6. Annual/Comprehensive…….this inspection must be performed by a qualified person and must be documented. Disassembly is required, as necessary, to complete this inspection. All of the following must be inspected:
a. Crane structure
b. Sheaves and drums
c. Pins, bearing, retainers, shafts, gears, rollers, etc.
d. Brakes and clutch components such as linkage, lining, actuating cylinders.
e. Safety devices and operational aids for proper operation and significant inaccuracies.
f. Engines for proper operation.
g. Chains, drive sprockets, idlers for excessive wear.
h. Travel steering, brakes, and locking devices.
i. Tires for excessive damage.
j. Hydraulic, pneumatic, or other pressurized hoses and lines.
k. Hydraulic and pneumatic pumps.
l. Hydraulic and pneumatic valves.
m. Hydraulic and pneumatic cylinders.
n. Outrigger or stabilizer floats for cracks and retainer problems.
o. Boom slider pads for excessive wear.
p. Electrical components for problems.
q. Warning labels and decals OEM supplied, missing or unreadable.
r. OEM operator’s seat or equivalent missing.
s. Operator’s seat – unserviceable
t. OEM ladders, steps, handrails, guards, missing.
u. Steps, ladders, handrails, guards in unsafe condition
v. Wire rope….all wire ropes must be inspected. In the event it is not possible to inspect a wire rope because of crane configuration, it can be noted on the inspection report that it must be inspected when the boom it lowered but not to exceed 6 months.
w. This inspection must include a functional test. If any deficiency is identified, an immediate determination must be made by a qualified person as to whether the deficiency constitutes a safety concern. If it is determined the deficiency is a safety hazard, the crane must be taken out of service until repairs are made.
As before, the crane inspector is responsible to inspect the crane based on your knowledge, experience, manufacturer’s guidelines, and the regulations for the specific type of crane that you are inspecting. Inspectors must all know their individual limitations and also be able to discern whether they fit the category of a qualified person for a specific type of crane. i.e. an inspector may be very capable and “qualified” to inspect a telescopic boom crane but doesn’t have the knowledge or background needed to inspect a lattice boom friction crane. To be qualified to inspect all crane types takes years of experience along with training.
As I said a while ago, OSHA always looks at things from a performance standard point of view. They give a set of guidelines as to what they expect, sometimes the guidelines are very specific and sometimes they are not. When they are not, it is left up to the employer to determine how the expected results are accomplished and who is qualified to accomplish them. Of course, when an accident happens, one of the first things OSHA will look at is what procedures were in place and who the qualified people were. I.e. If I am the inspector that will be doing the post assembly inspection on an 18000 Manitowoc and I have never assembled a lattice boom crane before, am I qualified to do the inspection. Suppose this crane was not assembled correctly and an accident happened.
Because the new regulation has a requirement that says cranes must be inspected after assembly by a qualified person, it is reasonable to say, OSHA’s intention here is to have someone familiar with the assembly of lattice boom cranes perform this inspection, specifically an 18000 Manitowoc . If the person that performed the inspection had no knowledge of how an 18000 Manitowoc is to be assembled, then by OSHA definition, they did not meet the performance standard of a qualified person in this task. Performance standards are usually evaluated after an accident happens. I believe this new regulation gives inspectors more guidance, although, it is impossible to make the entire crane inspection process black and white. Many times during an inspection, you are going to have to apply your judgment, and sometimes your judgment call will make the owner unhappy, but do not be afraid to make the decision. There are crane owners and end users that will try to intimidate you. Stand your ground.
We talk a lot about improving the crane inspection business. We all know the guys that are in the field inspecting cranes that have no idea what they are looking at. I believe one of the reasons this continues to happen is there is not enough awareness within the crane industry as to what constitutes a quality crane inspection. Heck, many safety managers and equipment managers don’t even see the inspection report after an inspection is done. They just assume because the crane was inspected, it must be ok. The process breaks down somewhere between the inspector and the equipment manager. Many General Contractors are looking at this issue and they are beginning to ask the hard questions.
Finally, when doing you're inspections, be professional and know that you know you have inspected the machine in its entirety and applied the regulations to your results. Don’t cut corners. You are not helping anyone by doing a slip shod inspection
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