The federal Mine Safety and Health Administration (MSHA) recently issued an equipment/safety hazard alert about an incident in which a mechanic sustained injuries when the boom of his service-truck’s crane dropped as he was positioning a transmission in a mining truck. The alert included a number of precautions that might have prevented the accident, among them were operating within the limits of the load chart, correcting known crane defects prior to use, and never placing yourself in the fall zone—anywhere an errant load (or boom) can land.
The incident calls attention to safe operation of service cranes, those relatively small telescopic models, typically mounted on a mechanic truck, that can range in maximum lift capacity from perhaps 1,000 to 14,000 pounds and in horizontal reach from 6 to 30 or so feet.
Service cranes have received publicity lately with the announcement from the National Commission for the Certification of Crane Operators (NCCCO) that it has developed a specific certification program for service-truck-crane operators. In addition, another certifying organization, Crane Institute Certification (CIC), now also offers a program for service-truck-crane operators, says James Headley, a member of CIC’s governing committee and director of the Crane Institute of America.
Present requirements, exclusions
As the latest federal rule now stands—OSHA’s Cranes and Derricks in Construction, 29 CFR Part 1926, Subpart CC, Section 1926.1427—all crane operators are obligated to be “qualified or certified” by November 2014, provided the crane being used is covered by the rule, has a lift capacity in excess of 2,000 pounds, and is employed in construction-related activities.
ASME B30.9-2010 addresses the selection, use, maintenance, and inspection of all types of slings: alloy-steel chain; wire-rope; metal-mesh; and synthetic. Although the industry strongly recommends inspecting slings before every use, a documented periodic inspection (not exceeding one year) is required.
Apparently, slings with serial numbers—alloy-steel chain and metal-mesh—must be individually documented, but opinions differ about required documentation for slings that typically have no serial numbers—wire-rope, synthetic rope, synthetic web, and synthetic round-slings. Sling manufacturers are the best source of advice about inspection frequency and documentation, especially for non-serial-number slings.
Bob Jasany, technical coordinator for the Web Sling & Tie Down Association (WSTDA), notes that applying serial numbers to synthetic slings is becoming a more common practice among manufacturers, and that some manufacturers are imbedding radio frequency identification (RFID) chips in synthetic slings, which, he says, “revolutionizes the way to conduct sling inspections and track equipment, compared with traditional paper-based inspections.”
That date likely will be pushed out three years, however, because OSHA has committed to reopening discussion about Subpart CC to clarify two points of concern being voiced by the crane-using industry: whether operator certification requires testing by both crane type and capacity, and whether a “certified” operator is also a “qualified” operator.
Subpart CC, however, contains an exclusion clause related to service cranes that continues to stir debate within the industry. Section 1926.1400 (c) (9) excludes “Mechanic trucks with a hoisting device when used in activities related to equipment maintenance and repair.” Thus, operators who use these cranes exclusively to “maintain and repair” equipment are technically exempt from certification.
Some in the industry believe that this is an instance in which the letter of the law has superceded the spirit of the law, which is intended to make all crane operations safer. And, too, they say, the letter of the law likely will be transgressed as well, because sooner or later, the mechanic probably will yield to requests that place the crane in a construction activity—“since you have your crane here, do us a favor just this once and lift this roof truss.”
“We encourage all service-crane operators to become certified,” says Tim Worman, business development manager at Iowa Mold Tooling Co. (IMT), and among the 17 industry experts who served on the Service Truck Crane Operator Work Group during NCCCO’s development of its new program. “It’s not that expensive, and even the best operators can learn to be safer and more proficient at their jobs, because certification requirements are comprehensive, including rigging fundamentals and proper inspection techniques.”
According to NCCCO’s Joel Oliva, manager, program development and administration, the new program is aimed specifically at the knowledge and skills necessary to operate a service-truck crane, and so far, industry response has been favorable.
But how does NCCCO respond to service-truck-crane users who avoid the certification issue by saying that their cranes are used only in repair situations, or that the prospect of certification being pushed out to late 2017 makes it a non-issue at present?
“We hear that all the time,” says Oliva, “and from a regulatory standpoint, they’re correct; if their work falls under service/repair, certification is not required. But that argument ends there. The fact is, well before national regulations were set, equipment-operator certification was proving to yield significant benefits—safer operations, reductions in insurance and maintenance costs, and productivity improvements—all well documented. Attention today is on regulation, but it’s not a regulation issue—it’s a safety issue.”
IMT’s Worman adds yet another benefit of certification, this one very practical: “There are job superintendents out there telling service mechanics, ‘I don’t care what OSHA says, if you’re not a certified operator, don’t come onto my job site.’”
In addition, says Worman, “MSHA and a number of state utilities seem on the cusp of implementing Subpart CC with no exclusions. It’s possible that a ‘no-exclusions’ approach could require service-crane operators not only to be certified, but also to be ‘qualified’ riggers.”
Worman also advises service-crane users to be aware of any pertinent local or state regulations regarding operator qualifications; if these regulations are more restrictive, then they trump the federal rule.
Off the hook for inspection?
A few service-crane users are of the opinion, that since service cranes used in maintenance/repair operations are seemingly exempt from all requirements of Subpart CC, then these cranes are not subject to the inspection requirements in Sections 1926.1412/1413.
This opinion is both false and dangerous.
“If service-crane users think they can hang their hat on the exclusion in order to avoid Subpart CC inspection requirements,” says IMT’s Worman, “then they don’t realize that prior regulations, still very much in force, do, indeed, require service-crane inspection—such as OSHA 1910 and ASME’s [American Society of Mechanical Engineers] B30.5, which supports 1910.
“ASME B-30.5-2.1 regarding crane inspection has been around for a long time,” says Worman, “and the language is copied nearly verbatim into OSHA 1910.180 (d), and both are the basis of the inspection requirements in Subpart CC. Every service-crane manufacturer places forms in their manuals for inspections—shift, weekly, monthly and annual—with sections for logging deficiencies found, corrective action taken, and date completed.”
In capsule form, Subpart CC requires that a “competent” person inspect the crane each shift, noting among other items: proper functioning of controls; leaks in fluid and air lines; damage to hooks, latches and wire rope; and proper functioning of operating aids. A monthly inspection repeats these requirements, but requires documentation that must be retained for three months. At least every 12 months, a “qualified” person must perform a comprehensive inspection, and the resulting documentation retained for one year. Depending on the severity of deficiencies uncovered in any inspection, the crane might be grounded until repaired, or the deficient conditions might have to be regularly monitored and documented.
“On the practical side,” says Terry Cook, IMT product manager of commercial products, “if a crane user follows the manufacturer’s inspection guidelines, potential safety or operational issues will be uncovered early on, and nine times out of ten, issues can be resolved well before failure.”
Cook reminds service-crane owners, again, that more restrictive local or state regulations for inspection might apply, and that although MSHA uses OSHA as a guideline, the former might have more stringent requirements, simply because of the potentially dangerous environments it regulates.
“What can happen when you have the dovetailing of regulations, as between OSHA and MSHA,” says Cook, “is that much can be left to the interpretation of the inspector, such as the requirement that a service crane display a certification tag that verifies annual inspection.”
Worman says that part of MSHA’s concern seems to be that of making certain that cranes comply with the original equipment manufacturers specifications, “because operators have a tendency to modify cranes to get the job done and not let their manufacturers know.”
“Operators also have a tendency not to inspect their cranes at the intervals recommended, because they’re rushing to get to the next job,” says Worman, “so wire rope gets frayed, maintenance schedules aren’t kept up, and rotation systems get sloppy. Eventually, something’s going to break.”
Dan Root, president of QT Equipment, a builder/distributor of service trucks in Akron, Ohio, says that from his perspective, MSHA is very serious about annual crane inspection, and he sees more and more companies that use service cranes also becoming more diligent about inspections, recognizing, he says, that small problems caught early and inexpensively can avoid costly catastrophic failures.
But that said, Root also notes that many of his customers have fundamental questions about inspection:
“There’s a fair amount of confusion regarding proper procedure and documentation,” says Root. “Customers are asking such questions as who’s qualified to perform crane inspections, must cranes be inspected when new, and is there standard labeling for approved cranes. Our industry would benefit from clarification of such issues.”
Informative Web Sites
Service-crane owners/operators can review the outline of the NCCCO written test for service cranes and watch a video of practical test requirements at these respective sites:
OSHA 29 CFR Part 1926, Subpart CC is available at: www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=14212