OSHA's 1971 Construction Standard Subpart N (1926.550-555)-Cranes, Derricks, Hoists, Elevators and Conveyors (including "skycranes" or helicopters) has not been updated for 34 years. Yet over three decades of technological advancements have occurred in the crane and hoist industry. The cranes being driven out of the assembly plants at Grove, Manitowoc, Link Belt, Krupp and Liebherr, are not your grandfather's or even your father's models.
Congressional Intervention
OSHA's currently enforced 1971Subpart N was based on previous industry consensus standards established in the 1960s and is considered by many within the crane and hoist industry to be obsolete. At that time the mobile hydraulic crane was not a predominate device on most construction sites. The Advisory Committee for Construction Safety and Health (ACCSH) then worked for several years with many stakeholders in the industry to consider changes in crane work practices and technology to improve the standard. As early as 2000, Congress was considering changes to the standard. The Negotiated Rulemaking Act also mandated that qualified members of the general public be offered a reasonable means to caucus and consult with the committee at specific times and places. On July 13, 2004, OSHA's Crane and Derrick Negotiated Rulemaking Committee (CDAC) had reached a good-faith consensus on language, format and content for these revisions.
The 15-25 stakeholder members of the CDAC included crane and derrick manufacturers, technical service providers, rental and leasing companies, crane and derrick owners, contracting firms utilizing cranes and derricks, construction labor organizations and unions, power and utility organizations, civil/structural engineers, crane operator training and testing organizations, as well as OSHA and other government agencies. The use of a professional mediator/facilitator (Susan Podziba) in its rulemaking session helped to facilitate the process of negotiation and the committee reached consensus on many of its target issues in a year. The committee successfully identified and prioritized many of the areas that required re-evaluation in Subpart N, while some others are still yet to be resolved.
The CDAC Consensus Proposal
The CDAC members finally offered their proposal to the director of OSHA in July 2004. The 119-page document may be downloaded by accessing http://dockets.osha.gov/vgoo1/V046A/00/48/45.PDF. There are 41 different sections and any thorough analysis of this report would be lost in an article as brief as this one. The general areas of interest can be summarized, however, keeping in mind that this a preliminary draft of a proposed regulation that will undergo further agency reviews before even the proposed rule is published in the Federal Register for public comment. Some of the key provisions of the CDAC proposal are:New Definitions
This broad new standard requires updating much of the technical language formerly not included. While many of the terms remain the same, the scope of what comprises a "crane" or "derrick" has expanded to include new equipment and designs and so has the terminology. The proposed rule excludes wheeled and tracked loaders, excavators, and backhoes when used with rigging to hoist or lower (such as pipelines). The overall roles of crane-site personnel (see below) are initially outlined in their definitions, however, the complete work practices of various designees are defined in more detail within the body of the proposed rule.Designated Personnel
You may find big changes here. I first read the document and created a roster of personnel who were designated by the employer and had clearly identified rights and obligations under the standard. These include: employer, employee, controlling entity, equipment operator, rigger, signal person, spotter, auditor, government licensing office, trainee/apprentice; operator's supervisor; trainee's supervisor; A/D supervisor; repair/maintenance worke,; equipment manufacturer, and registered professional engineer. Most of these personnel would be further categorized under OSHA's base definitions as qualified person, competent person, or authorized (appointed) person. A fourth category called "competent-qualified person" was additionally created just for this standard. Compliance directives to the Field Inspection Reference Manual will soon be distributed to every OSHA Area Office to clarify these designations and their assigned roles of responsibility.Qualified Person (QP)
This designation certainly covers a lot of ground in the proposed rule:Equipment operators shall be an employer-designated QP.
Designated assembly/disassembly rigger shall be a QP.
Designated signal person shall be a QP.
Designated equipment maintenance and repair personnel shall be QP.
The QP:
Develops the site-specific, crane-specific assembly/disassembly procedures.
Determines minimum clearance distance from power lines (all voltages).
Power line owner/operator, who holds planning meetings to determine safe-work practices.
Inspects modified equipment and performs function testing.
Inspects all repaired/adjusted equipment and performs function testing.
Determines criteria if a registered professional engineer is required to modify equipment.
Performs post assembly inspection by means of manufacturers' specification.
Performs annual equipment inspections.
Makes immediate determination if inspection deficiency is a safety hazard.
Monitors equipment that has been repaired to verify safety.
Monitors equipment that is used in "severe service" (use and condition).
Inspects equipment that has been out of service for more than three months.
Inspects and assesses wire rope (Category II) defects in order to put in or take out-of-service.
Selects/installs replacement wire rope to manufacturer's recommendation.
Documents all lifts made with wire rope with a design factor
Certifies anchoring PFAS to the load line of the crane meets 1926.502.
Audits qualifying crane operators obtaining certification by means of a written, observed and verified certification program.
Regularly evaluates equipment operators on site and documents the results.
Regularly evaluates signal person on site and documents the results.
Performs all training and re-training of personnel who are untrained or deemed not qualified or uncertified.
Initially trains and retrains on a regular basis all CPs and QPs in the standards applicable to their duties.
Structurally designs/approves personnel platform to be hoisted by crane.
Trained to occupy and operated a personnel platform that has controls.
Determines if either a wind speed >20 mph or any other severe weather condition will adversely effect the personnel platform.
As the lift supervisor, conducts a pre-lift meeting with the operator, signal person and all other authorized lift personnel.
Develops and implements a multiple crane lift program.
Determines when/if it is safe to hoist and place load without safety latches.
As an RPE, approves and supervises assembly/disassembly of a tower crane according to the manufacturer's inspections.
Approves assembly/disassembly and elevated access during high winds.
Temporarily estimates wind speeds until approve anemometer is installed.
Develops all necessary load anchoring data for each derrick installation.
Evaluates swing hoists after any repairs and modifications for load capacity and safe operation.
Determines if any load test is required on repaired/modified derricks.
Determines if pontoon/barge defects are considered hazardous; and if not hazardous, inspects monthly.
Inspects internal portion of floatation vessel once ever four years.
(Marine PE) Certifies all floatation vessels supporting ground-based cranes.
Evaluates load capacity of land cranes as per stability of vessel or floatation device including maximum allowable list and trim.
Designs and approves method of physical attachment of crane to barge or floatation vessel.
Designs and implements plan for auxiliary cranes on deck of floating crane.
Develops an operational control plan for derricks when the manufacturer's operational guide is unavailable on site.
Directs the implementation of safe live power line proximity procedures.
Performs pre-shift equipment inspection, including disassembly if required.
Determines if any equipment deficiencies discovered constitute a safety hazard (out-of--service).
Visually inspects, pre-shift, all wire rope and determines if any defect constitutes a safety hazard (out-of-service).
Determines if it is safe for the operator to leave the controls while the load is suspended while instituting measures to restrain boom/hoist, telescope, swing, outrigger functions.
Secures equipment whenever local storm warnings are issued.
Determines when slack-rope condition requires re-spooling of hoist drum.
Determines if wind, ice or snow effect equipment stability or capacity.
Supervises operation whenever equipment travels with load suspended by reducing load ratings, load position, boom configuration travel speed.
As lift supervisor, agrees on all signals with the operator and signal person.
Verifies that all fall protection anchor points meet 1926.502 requirements.
Approves all personnel platform hoist routes and safety devices, minimum load capacities, load boom radius.
Visually inspects personnel platforms for defects before and after trial lift.
Verifies proof testing results prior to platform occupancy.
Verifies it is safe for employees to enter danger areas of tower crane.
Supervises and inspects daily all derrick operations.
Evaluates wind speed and direction on all floating cranes and barges.
Makes daily and monthly inspection for defects on floating cranes and pontoon/barge vessels.
All personnel designated on the crane assembly/disassembly crew shall be CQPs.
The employee designated assembly/disassembly supervisor shall be a CP.
Some of the CQP's specific duties may include:
Conducts planning meeting prior to assembly/disassembly to prevent electrical encroachment.
Supervises multiple crane lift plans or else a CP supervisor assisted by one or more QP assistants.
Supervises all operations involving a jumping derrick.
Crane specifications, features and manufacturer's general technical information
Crane controls, instrumentation and limiting devices
Equipment inspection procedures
Wire rope, rigging devices and procedures
Machine power flow systems
Equipment-specific attachments
Live/dead load capacities and their dynamic effects on the equipment
Obtaining and evaluating important crane site information
Communication equipment and operations
Protocols for changing site and environmental conditions
Shutdown procedures for unattended equipment
Use of load charts and override capacity verification
Crane specific operational procedures (i.e., operating over/under water, demolition, pile-driving, concrete delivery, etc.)
Competent Person (CP)
The CP is an employee designated by the employer and who is capable of identifying existing and predictable crane/hoist hazards in the working conditions that are hazardous or dangerous to employees. The CP has the employer's authorization to take prompt corrective measures to eliminate them. In this proposed rule, the CP:Competent-Qualified Person (CQP)
The CQP is an employee designated by the employer and who has met the obligations and qualifications of both the CP and QP in order to either perform or supervise crane/hoist assembly or disassembly. Crane and Derrick Ground Conditions
This subject is further clarified regarding the structural analysis of the support ground, control and access permitted around a crane pad and the nature of the "fall-zone" below the boom and jib. Minimum ground resistance requirements are established to prevent tip-over during use as well as the structural limitations during assembly and disassembly of the crane. Unknown, undiscovered and perhaps abandoned subgrade structures (i.e., culverts, tanks, vaults foundations, etc.) are of particular concern. The qualified operator should never assume the subsoil conditions are adequate simply because some random soil tests were conducted. The use of ground-penetrating radar is often recommended prior to selecting a crane pad in heavily built-up areas or locations where a significant fill was placed (rivers, harbors and lake or ocean frontage). The descriptions of "acts" and "conditions" in these sections seem fairly graphic and therefore capable of understanding and achievement.Electrical Hazard Identification and Mitigation
The revisions here have highlighted the operation of equipment assembly and disassembly, stationary operations up to and over 350 kV as well as using the crane near electrical conductors. Electrocution under 600 volts is the number one cause of crane accidents in the United States, so you can expect to see some improved details here. Crane Operator Qualifications and Certification
Section 1422 and Appendix A are, and still remain, the most contentious areas of negotiation for the committee. Camps were established on both side of the operator certification issue, clearly separating the constituents and their vested interests. The National Commission for Certification of Crane Operators (NCCCO) is the only organization currently qualified to test and certify crane operators, but not their training. It will become an OSHA violation if you operate a crane/derrick without an operator's certification from a reputable, approved auditor or accredited agency. There is also no "grandfather" provision in this preliminary proposal, thus requiring even experienced operators to be re-tested before continuing their operator function. There will be further discussion of this issue by many contractors and unions in a public comment period before this portion of the final draft is prepared and accepted.Crane Inspection
Who? What? Why? Where? When? How? How much? This pretty much covers this scope of this subject. The documentation here is critical. Not only does the physical plant of a crane require inspection, but also so does the performance of the lifting tasks within the manufacturer's specifications. A performance language definition of "competency" states that the competent inspector (auditory) should be capable of completely describing the crane job in exact detail as many as three years after he has completed his inspection. When he has finished documenting, he should then document some more. Some of the inspection details include wire rope, hooks and fasteners, hoisting equipment, controls, trucks, booms and frame/houses, equipment modifications, and miscellaneous manufacturer-approved attachments.Crane Operations
There are a great many configurations in which cranes, hoists and derricks may be used in construction. The proposed rule attempts to identify most of them and discuss the safe work practices and prohibitions they considered necessary. Additional Species of Cranes
This category includes overhead and gantry cranes, articulating cranes, self-erecting tower cranes, pile-drivers, floating cranes and land cranes on barges, side-boom cranes, gin pole derricks, guy derricks, stiff-leg derricks, Chicago boom derricks, swing hoists and cranes with lifting capacities less than 2,000 pound such as tire service trucks. The standard addresses those hazards specific to these species as well as assembly, dismantling, access and operational procedures. The tower crane section incorporates details on erecting, climbing and disassembly rather than assembly/disassembly.Crane Hazards
There are a multitude of hazards identified by the negotiating committee including: jib and boom erection; foundations and structural support; backward stability; wind and weather considerations; plumb tolerances; multiple crane sites; approved climbing procedures; counterweight analysis and installation; miscellaneous required safety devices; and operational aids, such as proximity alarms and load or travel limiting devices.Signals
The eventual regulation will stipulate the standard ANSI international crane hand signals as mandated. Appendix A addresses the use of non-standard signal methods, whenever standard signals are infeasible due to various ambient light or environmental conditions.Operator's Certification Exam
Appendix Q contains criteria for the employer to use to develop a written and performance examination of his crane operators. It is addressed to employers, accredited testing organizations, QP auditors and government agencies. These broad-ranging, non-mandatory recommendations are quite technical and specific to the type of crane in which the operator has selected to be certified. Examination categories include:Emergency Response
This is one area of the standard that I believe could undergo further development. While there is no one specific section which addresses the employer's Emergency Action Plans for crane sites, mention is made in various locations to some hazard response requirements, such as fire prevention and power line contact. The details of these response procedures are quite vague and more emergency issues should be considered. These would include loss of stability, tip-over, control malfunctions, two-block failure, gross overload, lattice boom collapse, carrier and travel malfunctions, outrigger failure, crane pad cave-in/settlement, and wind-load moment effects. Recent construction crane emergencies around the country have illustrated the need for more specific personnel rescue procedures, such as: high-angle rope rescue, PFAS and suspension trauma, emergency communication systems, security measures for tipped equipment and collapsed structures, and crane-specific emergency response team criteria.
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