OSHA Issues Long-awaited Compliance Directive for Cranes and Derricks in Construction Standard

In late October, OSHA finally released its compliance directive for enforcement of the 2010 Cranes and Derricks in Construction standard.  Basically this is a document which tells OSHA compliance officers how to inspect a construction site that has a crane(s) working on it and what to issue citations for.  This is a crucial document for employers to become familiar with in order to keep worksites safe and avoid citations and fines. 

The following is an excerpt from the directive listing an abbreviated inspection checklist for compliance officers.  If you are a previous New England Crane School customer for signal/rigging classes, please be sure to note the highlighted item below.

At a minimum, the following items should be considered for any abbreviated compliance inspection of a worksite on which there is a crane. This information can serve as the basis for development of related inspection checklists. However, whenever a fatality investigation, complaint/referral inspection is conducted, or when hazardous conditions on the worksite warrant, the Compliance Officer maintains the discretion to expand the scope of the inspection to include all other applicable requirements of the crane standard. In addition, the Inspection Guidance and Citation Policy section of this compliance directive must be referenced for more requirement-specific guidance.

B. Abbreviated Inspection Checklist.

1. Determine the adequacy of ground conditions beneath the equipment set-up area such as the support/foundation, matting, cribbing, blocking, etc.

2. Check for visible indications of repairs of the equipment.

3. When overhead power lines are on the construction site, ask if the utility owner/operator was contacted and if the lines are energized. Obtain the voltage of the power lines (if known). Verify whether a work zone around the crane was demarcated and what encroachment prevention steps are being used.

4. When a signal person is used on the worksite, verify the individual’s qualifications/documentation. Acceptable documents include both physical and electronic records.

5. Verify that the communication system being used by the crane operator and the signal person is the one specified on the signal person’s qualification documentation. (Note from New England Crane School: if you attended an NECS signal/rigging class prior to 2013, your card may not comply with this requirement. Please contact us immediately for a replacement card.)

6. If lift plans are being used, verify that they are being followed.

7. When equipment is used to hoist personnel, identify who determined that it is infeasible to use another way to reach the work area and that it is necessary to use the crane for this task. This does not apply to steel erection activities under Subpart R.

8. Verify whether employers are holding required meetings, such as planning meetings necessary for working near overhead power lines, conducting Assembly/Disassembly (A/D), or hoisting.

9. Inspect all rigging equipment that is available for workers to use (slings, chokers, shackles, etc.) for damage, wear, safe working load tags, capacity, and safety factor.

10. Verify that load chart and operations’ manuals are available, written in a language that the operator understands (specified on the operator’s certification), and that the information is applicable to the particular crane. Ask the operator or employer where the documents are kept. For example, see if the serial number on the load chart matches that of the crane. Typically, the serial number is found on the nameplate in the cab and on the front cover of the manual.

11. Verify operator qualifications and training. Observe crane operations and interview both the employer and the operator to determine whether the operator is competent to operate the equipment safely.

12. Verify that the equipment and wire rope inspection requirements have been met and that the documentation is available for all inspections of the equipment. Identify who did the inspection and verify that inspector’s qualifications.

13. Determine, through interview and observation, if safety devices and operational aids are functioning through interview or observation. For example, it is possible that employees can be doing other things to compensate for aids and devices that are not functioning properly. For operational aids that are not functioning and have not been repaired, determine whether parts are on order. If parts have been received, document the date of order and/or receipt.

14. Visually inspect the hoisting equipment, components, and load line for visible deficiencies. If needed, use binoculars to examine ropes that cannot be inspected closely from a safe position.

15. Ask what loads have been lifted and how the operator and/or rigger are determining the weight of the load. For example, are they using a bill of lading or marked weight, the load moment indicator, or crane scale? Verify that the weight of the load(s) was within the capacity of the equipment or below 75% of capacity if a load moment indicator was used.

16. Verify that qualified riggers are being used:

1. For assembly and disassembly work, as per § 1926.1404(r)(1).
   
2. Whenever workers are within the fall zone and hooking, unhooking, guiding a load, or making the initial connection of a load to a component or structure, as per § 1926.1425(c).

17. When A/D is being performed, ask who the A/D director is and verify whether this person is at the worksite. This could be one person or a competent person who is assisted by one or more qualified persons.

18. If there are mechanics and/or oilers working on or near the equipment:

1. By observation and interview, verify their qualifications regarding the work being performed.
2. Ask how they are communicating with the operator when the equipment is being operated.
3. Verify that they are being protected in hazard areas in accord with §§ 1926.1404(e) and .1424(a).

19. If fall protection is being used, inspect personal fall arrest systems for compliance with Subpart M at § 1926.502(d). Note that the anchorage requirements at § 1926.502(d)(15) do not apply; the applicable anchorage requirements are at § 1926.1423(g). The requirements for boom walkways, handrails, steps, ladders, and railings, etc., are in §§ 1926.1423(b) and (c).

Often the crane standard refers to key individuals, such as an Assembly/Disassembly (A/D) director, lift director, equipment inspector, operator, registered professional engineer, or qualified rigger to make determinations related to the capacity and safe use of the equipment. Such individuals must meet the definition of qualified or competent persons, and interviews should be conducted to document the relevant credentials and level of experience of these individuals as support for a potential citation. For example, the individual should be asked to describe:

• his or her relevant experience with the equipment at the site or similar sites,
• his or her qualifications to perform the activity or make the required determination,
• the extent and duration of his or her crane-related experience, and
• any certificates, degrees, or other supporting documents related to the subject matter.

The full directive can be read here. Have questions or need help?  Call or email New England Crane School at 603-614-4331, anna@newenglandcraneschool.com.