Thursday, May 5, 2011

VERIFICATION OF DEFICIENCY CORRECTIONS

BY: JOHN W. DAVIS, PE for the Crane Certification Association of America (CCAA)

It is often very difficult for surveyors to decide on a suitable way to verify deficiency corrections. Some aspects of correction verification are defined by safety regulations or consensus standards. In many instances, however, the decision is left to the best judgment of the surveyor based on a reasonable concern for safety and defensibility. If an accident should occur which brings into question the effectiveness of the safety survey, documentary records are the most certain way to show that the survey and follow up verifications have been diligently accomplished.

The decision frequently involves financial considerations. It is often necessary to make another on-site inspection. Sometimes it’s necessary to assemble adequate test weights and witness the load test. Occasionally the crane may have been moved to another, more distant location. Regardless of the obstacles and financial burdens, the cost of an accident trumps the additional survey costs every time. The best answer to this dilemma is a contract or proposal that specifies how the additional costs will be invoiced.

One of the most difficult issues that plagues the surveyor is how long delinquent deficiencies can remain uncorrected. How long is too long? Should he remind the client of the need to address deficiencies? How often? It’s clear that hazardous conditions must be corrected before the crane can be returned to service. The dilemma arises with deficiencies that are not immediately hazardous. Such things as labels, decals, placards, and worn or damaged components are examples of deficiencies that may not be immediately hazardous. Withholding the certificate of compliance usually motivates the user to make the corrections expeditiously. However, in those jurisdictions that do not require a certificate, some surveyors use a written follow up
reminder system at 30-60-90 day intervals with appropriate warnings regarding potential consequences of noncompliance.

Another difficult issue is by what means should correction verification be achieved. Under what circumstances is a functional/load test needed? Is an inspection of the corrections required in all cases? Is a signed statement or signed off deficiency report by the user sufficient? Do copies of purchase documents provide sufficient proof of corrections? Here again the surveyor is faced with a judgment call for which there is no single correct answer. If structural repairs due to wear or damage of load bearing members (other than hoist ropes) are done, a 100% load test is required. This test should load the repaired member(s) at 100% capacity and should b e appropriately documented.

Finally, there is the issue of what form of documentation should be used to memorialize the verification of the deficiency corrections. Should the functional test be described and data recorded? Should the verification be integrated into the check list or deficiency report? Is a photo or phone call sufficient for non hazardous deficiencies? The answers to these questions depend on the judgment of the surveyor. Functional/load tests should always be documented with an appropriate statement as to the reason for the test and a brief description of the test itself. Many surveyors integrate a sign-off column in the deficiency report; the-sign off should be dated. Sometimes a photo or a completed work order constitutes sufficient verification. The use of this method is a judgment call by the surveyor and depends on the relationship between the surveyor and the crane user.

Effective procedures and good record keeping are at once burdensome and necessary. The extra time required to develop and execute suitable procedures, especially for correction verification, takes time away from productive activity. Record keeping is usually considered to be unproductive and the surveyor tends to minimize the function as much as possible. However, both of these functions are essential elements in the management of risk and provide evidence of quality service and the appropriate standard of care expected of the crane surveyor.

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