ANSI Interpretation 2-1

The following is an official Interpretation by ANSI issued to help clarify portions of the various ANSI codes. These are actual questions that have been submitted to the committee requesting further information on a specific part of the codes.

Interpretation: 2-1

Subject: ANSI B30.2.0-1976
Date Issued: March 19, 1984
Question: Can the B30 Committee allow relief from para. 2-1.10.3a of ANSI B30.2.0-1976?
Reply: ANSI-B30.2.0-1976 is of-and by itself, a voluntary standard and as such requires no relief from the B30 Committee. See Section II, Purpose, of the Introduction to ANSI B30.2.0-1976.
ANSI B30.2.0 may be cited by a regulatory body or by an administrative authority having oversight of the operation and thereby becomes an operating directive that must be observed. Note that the Federal Register Vol. No. 105 Saturday 29 May 1971 Section 1910.79g3i cites para. 2-1.10.3a almost verbatim and from this we may conclude that this is a workplace requirement.
The intent of para. 2-1.10.3a is to rewire an intentional and overt reset action by the operator in order to restart motion following a stop caused by a power loss. To have an unplanned restart condition is considered unsafe and should be corrected.
 In view of your history of no accidents and low usage rate you may wish to consider Section III, Exceptions and Interpretations, and Section IV, New and Old Installations, of ANSI B30.2.0-1976, as your basis for not modifying your present equipment.

COMMENTS:
The critical phrases here are “…becomes an operating directive that must be observed” and “… we may conclude that this is a workplace requirement.” Although the ANSI codes were originally written as “voluntary codes,” they have been “incorporated by reference” into the OSHA law by OSHA 1910.6 and thus are no longer “voluntary codes” but now have the full force of law behind them.

I find the introductory paragraph stating that B30.2 is a voluntary standard and therefore requires no relief, a distinction without a difference. The statement may be technically correct but misleading to the reader. All documents “incorporated by reference” in OSHA 1910.6 are just as much the law as the OSHA regs. In fact, because of the “incorporated by reference,” they ARE THE OSHA REGS!

NOTE:
The above comments are my opinion and only my opinion. They are offered to create a conversation among professionals in the crane industry and with this conversation, to help provided clarity to those that need a practical application of these issues. It is my intent to eventually review and discuss all the Interpretations and Clarifications of ANSI/ASME, OSHA and the CMAA. As always, I invite your comments via email to
Larry@OverheadCraneConsulting.com . 

Just Tell Me What to Do?

WHO’S REALLY IN CHARGE HERE?

For over thirty years, I was the owner of Dearborn Crane & Engineering, a manufacturer of overhead cranes. I have to admit to having a thin skin when it comes to news reports that take pot shots at “big, bad business”. You might be asking yourself, what this has to do with an engineering blog about cranes, but bear with me. I’ll be getting to the point real quick.

 

ENTER THE FIRE MARSHALL

Some time around the mid 90’s, the local Fire Marshall paid a surprise visit to do an inspection of my manufacturing facility. We had just completed our ISO 9000 Certification and practiced the 5P management program. In other words, we had a clean and organized manufacturing floor. I confidently walked the Fire Marshall to my shop, fully expecting a clean bill of health. 

Right off the bat, he wanted to go and see our above ground gasoline storage tank. I later found out that he spied the tank while driving by and the tank was what prompted the visit.

We had the tank for the purpose of fueling our lift trucks and mobile cranes. A decade earlier we had thought about putting in an under ground tank, but in light of all the horror stories about leaking tanks I was glad we had never made the switch.

So when he left, we had a 100% clear bill of health, with the exception of orders to eliminate the above ground fuel tank. As soon as the Fire Marshall left, I looked up IDEM, the Indiana Department of Environmental Management. After a few dead end calls, I finally got the right guy. The IDEM guy asked me a few questions and in less than five minutes, I was told our gasoline usage was too low to get a permit for an under ground tank. 

 

NOW IT GETS INTERESTING

I told the IDEM guy about my problem with the local Fire Marshall and relayed the fact that he would not allow me to have a gasoline storage tank above ground. The IDEM man’s response was “… I don’t know what to tell you about the Fire Marshall, but I’m telling you that you can’t put your gas tank under ground.” I was beginning to get exasperated. 

 

JUST TELL ME WHAT TO DO

I told him that I’m not fighting this, I just want to do the right thing. I politely said that I had the Mishawaka Fire Marshall’s card right in front of me and I could give him the Fire Marshall’s contact info. I asked if he would talk to the Mishawaka Fire Marshall and please compare notes on my situation. Once they decided on a course of action, one of them could give me instructions on what I have to do to comply with the law. 

I naively expected a response something like, sure, give me his number and I’ll get back with you in a couple days. Instead I got “we don’t do that, all I can tell you is that you can’t put your tank underground.”

I thought to myself; this was a downstate Indianapolis bureaucrat and I should have expected this, my local Fire Marshall will be a far more helpful person so I gave him a call. Little did I know that I was about to get the same answer from him! Well, almost the same answer. He said, “…I don’t care where you put it, but it can’t be located above ground!”

 

WHO’S IN CHARGE HERE… NO, REALLY, WHO’S IN CHARGE?

I recently wrote an article here on OSHA’s 1910.6 “Incorporation By Reference”. OSHA’s 1910.6 references over 200 other codes that through the legal concept of  “Incorporation By Reference” have the full weight of the OSHA spec. In other words, OSHA is not the 2344 pages in the 1910.00 book but rather tens of thousands of pages including all those specs being “Incorporated By Reference.”

 

ISO (International Standards Organization) EUROPEAN CRANE SPECS

What brought this topic up was last week I had a client in upper New York state that was hung up on the ISO SWP (Safe Working Period) calculations. I’ve had about twenty years experience with the ISO standards and the SWP calcs in particular. I ran the number for them and then explained the results on a conference call with a room full of their engineers and managers. They were shocked to hear the cranes they had me run the numbers on, all had an SWP calculated remaining life of almost -1000 days. That is, the hoists should have been replaced or undergone a “GO” (General Overhaul) about a thousand days ago.

Near the end of the call, I confidently said that although I thought the SWP system was the best method of quantifying hoist life, it’s a European standard. Because they were a New York company they really didn’t have to worry about SWP.

 

PULLING THE RUG OUT FROM UNDER ME

The first response was a collective sigh of relief from the group. That was until one of them said “… doesn’t OSHA say that we have to also comply with the manufacturers maintenance recommendations?”  I quickly retorted, that’s not just OSHA, there’s a similar statement in CMAA 70, CMAA 74 crane specs and the HMI HST 4 hoist specifications. 

 

OSHA 1919.179(l)(2)(i)
A preventive maintenance program based on the crane manufacturer’s recommendations SHALL be established.

 

As soon as the words left my lips, my brain telegraphed a sickening feeling directly to my gut. I had just opened one huge can of worms! For the first time it dawned on me that if you have a crane with a European hoist such as a Kone or Demag, and they have ISO requirements such as the SWP calculation for useful life in their Owners Manual (and they all do), then you are subject to the ISO requirements as well as OSHA and all the other documents Incorporated By Reference!!!

PUTTING ON MY EXPERT WITNESS HAT

Now lets just imagine that you had a dropped load, crane accident (like my NY client). The crane has had normal maintenance and it still has it’s original motor, gearbox, brakes, etc. It was a good piece of equipment and ran like a top, prior to the accident. 

Now the widow’s lawyer is suing your company and the plaintiff’s expert witness reads the Kone owner’s manual and runs the SWP calcs. He runs the numbers and it says the hoist had a -837 day estimated remaining life (yes, that’s a negative number).

At this point the question changes from guilt or innocents, to how much will we have to pay, will our insurance cover the claim and how much will my rates be going up? The question might even be, when does negligence in a workplace safety accident result in not civil, but criminal charges?

 

In other words, YES, if you own a European hoist (or Japanese, Korean, etc), you are subject to those specs too, and you better start doing your homework…NOW.

 

PS

By the way, I never got an answer about above ground gasoline tanks vs. under ground tanks. I finally gave up and changed all my equipment over to LP gas. 

Some times the real challenge is not how to conform to the law, but knowing what law to conform to? In other words, “Who’s really in charge here?”

 

The Crane Guy

 The Crane Guy

The Crane Guy

INTRODUCING "THE CRANE GUY"

Today, I'm introducing "The Crane Guy." Promoting a one man, engineering and consulting firm is at best, challenging. Especially when the business involves a service like crane engineering and crane related expert witness assistance. 

OUT OF SIGHT, OUT OF MIND

Cranes are not on our daily radar screen of needs, but when that day comes, the clients can't remember "that crane guy's" name. My solution is to use "The Crane Guy" in all my communications until Google gets the connection. 

THE GOOGLE MACHINE

When Google get's that relationship, you'll no longer have to remember my name, Larry Dunville or my website address, www.OverheadCraneConsulting.com,  or even  my email address, Larry@OverheadCraneConsulting.com.

All you'll have to do is to put "the crane guy" into the Google search box and the Internet will, through the assistance of the Google Machine, bring you to my front door.

Of course, you can still contact me in the following conventional ways;
Larry Dunville: Contact Info
Phone/Text: 574-210-8612
Email: Larry@OverheadCraneConsulting.com
Website: www.OverheadCraneConsulting.com
LinkedIn:  www.linkedin.com/in/LarryDunvilleTheCraneGuy

There's No Such Thing as a Free Lunch

WHAT'S THE REAL COST OF FREE?
or
What you don’t know, can bite you in the ass!

“There’s no such thing as a free lunch.”
...my Father, 1965

My Dad said that to me when I was about 15 years old, while driving down the road in his 1965 Chrysler Imperial. I silently repeated it to my self twice, trying to digest the meaning and thought, “What the hell is that suppose to mean?” He went on to tell me that during the depression (most of his stories came from either the depression or the war), that “blue collar” taverns would advertise free lunches, including plenty of salty pretzels, salty potato chips and salty dill pickles as well as sandwiches. His point was that the sandwiches weren’t free, the cost was just buried in the price of the beer, and with all the salty sides, the bar tender planned on selling plenty of beer.

THE FREE INSPECTION GAMBIT

Today we are besieged by “free lunch” offers, especially the “free inspections” variety. Free furnace inspections. Free brake inspections. Free roofing inspections. The “free inspection” is a business model that works and works well, but in fact it’s really just another form of “bait and switch.”

Customers are lured in with an offer of a free inspection, usually involving the analysis of a complex piece of equipment, and more often than not, are left with a sizable repair bill. A bill that involved no price shopping on the part of the buyer. In other words, a sellers dream sale.

WHY IT WORKS…OVER AND OVER AND OVER AGAIN

So why is this sales gambit so popular. Very simply, because it works. What are the components to that make this business model work? 
1. Asymmetrical Knowledge
2. Asymmetrical Resources
3. Complex Issue
4. Big Owner Risk
5. Fear of Consequences

ASYMMETRY

Asymmetry is the unequal power between two parties. In almost every “free inspection” situation, the service person has both knowledge and tools that the buyer just doesn’t have. This disparity gives great advantage to the service provider. The service provider's only problem is finding people in need of his services. This problem is unwittingly solved by the buyer because he has responded to the “free inspection” offer. In effect the buyers have “tipped their hand” that they’re already worried about the issue.

COMPLEXITY

Next, these are almost always complex pieces of equipment. Too complex for the owner to self evaluate the potential problem. After all, if they were not so complex, would you have to seek the assistance of an expert for a free evaluation? 

RISK

The last two components are closely tied together. The buyer is concerned about a complex and expensive issue. In other words, a big risk for the owner. Coupled with big risk is a “fear of the consequences” in the event of failure. 

In other words, if your brakes fail, your family is in danger. If your roof leaks, your house will incur damages, and if your furnace fails, you could have a gas explosion. Big risks and big consequences. 

INSPECTIONS AS A PROFIT CENTER

In the early 1990’s I started selling a crane inspection program to my past crane customers. My motivation was two fold, first I wanted to keep my skilled crane techs busy.  I needed a way to even out the ebb and flow of the work schedule and inspections seemed like the perfect tool. Secondly, it would be a zero marketing cost way to stay in front of past customers. We would regularly be at the past customer's plant with our service vans, keeping our name in front of both the maintenance and engineering departments. 

What we soon learned was that following the inspection, the customer rarely asked “how much” regarding the needed repairs, but rather “how fast.” Unfortunately, we were not the only crane company to learn this. Once it became known that this could be a significant new “profit center” for crane companies, it marked a “race to the bottom.” In other words, inspection pricing continued to decline in an effort to get the lucrative repair work. 

THE RACE TO THE BOTTOM

As inspection revenues declined, the conscientious  inspection firms were driven out of the inspection business. The aggressive inspection devised more and more disturbing levels of “bait and switch,” until they hit bottom. Todays crane inspection programs incentivize the crane techs by paying commissions on their hours and parts sold. Those that refuse to aggressively sell are subject to dismissal for not meeting sales quotas.

THE HIDDEN COSTS OF FREE

As soon as the seller introduces the “free” angle, the rules of the game change. The seller must make a profit to exist so the questions become, how to recoup the costs of the free inspections. At first glance, the owner of the broken furnace may think that she paid for the service repair as well as the inspection in the repair bill. No harm, no foul. But upon closer examination, that’s not the whole picture.

Let’s say a furnace company has to perform say five inspections to find one furnace that merits service. Further, it takes about ½ hour drive time each way and about one hour for the inspection, report generation and presentation to the customer. In other words, each “free” inspection costs the company two man hours. With a one in five hit ratio, the poor sap with the broken furnace is going to have to absorb all ten man hours (factored into the billing rate) in addition to the real costs of fixing their furnace. 

THE REAL COST OF FREE

The real cost of a free inspection is not the repair, but the inherent requirements of this business model. The inspector has been drilled on the fact that his paycheck ultimately depends on his billable hours and repair parts sales. In the old days, our inspectors would replace a capacity sticker or top off a lube reservoir and not even make a note on his report. Today, the tech can’t even replace a 39 cent cotter pin because it’s potentially a $25 repair when done on a work order after the inspection.
 
Worst of all, the inspector is not only incentivized to write up every “nit-picky” detail, but this report is now public documentation of every issue related to your overhead lifting equipment. In other words, the inspector has created a well documented paper trail that leads directly to your bank account in the event of a possible accident someday. In other words a plaintiff lawyer’s treasure trove.

THE SOLUTION

The solution is really quite simple. Create a wall between the inspection function and the repairs. Bear the real costs of inspection and then go out for competitive bids on the repairs. The total costs will be lower in the long run. It’s really that simple!

By paying for the inspection, you assure yourself of paying for what you get and getting only what you paid for.

SUMMARY

At the risk of mixing metaphors, never let the fox guard the henhouse. Or, like my Dad told me over fifty years ago,

THERES NO SUCH THING AS A FREE LUNCH!

…by the way, could you please pass those potato chips and pickles to go with my sandwich, and bartender, another beer please. For some reason, I’m really thirsty today!

Note to Self: It's the Runway Stupid!

40 Tons of SCARY CRANE NOISE overhead

I recently spent a week at a naval shipyard on a consulting contract. The client had three, 40 ton overhead cranes, span of approximately 125 feet, all on a single runway of 1000 feet. The end crane kept making a loud "snapping" sound when run on the eastern third of the runway. The noise was so loud that the client was afraid the wheels were climbing the ASCE rail and could possibly "jump the track."

After inspecting the crane, it was obvious that the crane had incurred one or more collisions  with either the other cranes or end stops and as a result, the end-truck diaphragm was visibly bent. Out of habit, part of my inspection process included checking the runway rail for signs of unusual wear. It was no surprise to find random accumulations of shavings along the runway rail indicating severe wear due to runway misalignment. In this case it was both bad runway alignment as well as a permanently skewed crane due to the bent end-truck diaphragm plates. Because the cranes were over a decade old, I couldn't tell if the shavings were recent or the result of a decade of wear. 

BUILDINGS NEAR WATER ARE ALWAYS MOVING

This runway wear was not a big surprise, after all it was a shipyard and located on the shores of a waterway. Buildings along waterways almost always experience moving footings and therefore constantly moving runways. This footing movement is often so severe that it doesn't take the use of some fancy laser measuring device to detect. Frequently concrete floors are cracked or the top of footing elevations significantly differs from floor level.

At the completion of my inspection, I asked the crane tech assigned to me to take a can of spray paint and mark each of the locations where the pile of shavings had accumulated and then to clean off the shavings. If, in a month, we saw a new pile of shavings we could gage the severity of the problem. I then wrapped up my inspection and promised to have a report the following week.

A SIMPLE ANALYSIS OF THE PROBLEM

The essence of the report was pretty simple. First to get the runways aligned and second to replace the bent diaphragm and bogey connector channel.

About three months later, I got an email saying that the replacement components had arrived and asked if I would supervise the crane repairs. We agreed upon a date and I submitted some names of runway alignment firms for the owners consideration. I suggested that the runways should be aligned prior to the structural repairs of the crane.

NO TIME TO ALIGN THE RUNWAYS

Upon arriving at the job site, I asked who they got to do the runway alignment? I was told that because of time and scheduling issues, they were forced to do the structural repairs first and the alignment later. I was concerned that the runways had not been addressed, but still felt confident that the skewed shape of the crane parallelogram was the root cause of the crane noise.

After three days of working around the needs of production, my crane techs and I finished our repairs. We pushed the bridge travel button and the snapping sound had not changed! The three of us were baffled and exhausted.

We decided to ride the crane and watch the "wheel to rail engagement" again, to see what we missed. We rode the crane for half an hour, took pictures and even recorded a video with my iPhone. Refocusing my attention from the structural repairs to the runways, I noticed there was a new accumulation of metal shavings at each of the locations the crane tech had marked three months earlier. We then headed back down for a skull session.

It was late Sunday afternoon and the three of us sat at a lunch table in an empty break room. The building was empty and the three of us were both mentally and physically running on empty too. After tossing around a number of ideas, I mentioned the piles of metal shavings along the runway rails. I said I wish they had the runways fixed prior to these repairs because it would have removed a number of variables from our equation. 

"HALF-ASSED" ALIGNMENT IS BETTER THAN NONE

The junior crane tech said he knew most of the runway J-bolts were loose and a few were even missing. The lead tech suggested we do a "half ass" alignment and tighten the J-bolts for just one bay to see if that had any effect. We couldn't think of a better idea, so we went back up in the lifts and did a  rough alignment, tightening all the J-bolts of the bay where the loudest noises occurred.

Upon completion of the single bay, we went back to the floor and started up the crane. I pushed the bridge travel button and we were shocked by what we didn't hear. Our "half assed" alignment reduced the snapping noises by at least 80%!!! Yes, there was still some snapping noise, but our alignment and tightening was crudely executed at best. 

We didn't have the time or the equipment to perform a full runway alignment, but we had reliable evidence that we had discovered the "root cause" of the noise as well and the abnormal rail wear.

SUMMARY: IT'S THE RUNWAY STUPID!

As a lifelong crane man, it serves my ego well to utilize my collection of engineering and manufacturing crane knowledge to focus on just the crane itself. After all, crane runways are just simple, dumb structures with no mechanical or electrical controls; no moving parts! But, more often than not, most crane problems can be traced back to a runway problem. 

In the 1992 presidential election, political pundits attribute Bill Clinton’s elections to his strategist reducing the election to one simple phrase, "it's the economy stupid."  

I need to remember this when diagnosing ailing overhead cranes, as my first line of investigation.

Larry… it's the runway stupid
Larry… it's the runway stupid
Larry… it's the runway stupid

 

The "Animal House" Guide to Understanding OSHA's General Duty Clause

There are two personality types when it comes to OSHA compliance. On one hand, there's the type that says, we'll worry about that when it happens. The other type proactively does their best with the byzantine world of safety mandates.  Since you’re reading this article, you must be one of the later.

We “second groupers” are trying to get our minds around the safety conundrum, but frankly, it's nearly impossible; maybe more impossible than you realize. Why so daunting? Three words… "General Duty Clause."

HISTORICAL PERSPECTIVE

OSHA was established by the Occupational Safety and Health Act of 1970, and its jurisdiction covers all private-sector employers, regardless of size. Practically speaking, OSHA can be divided into two parts, A) Specific Regulations and B) the General Duty Clause. In a nutshell, the thousand pages of OSHA regs exist to provide guidance in fleshing out the General Duty Clause.  

The General Duty Clause: Section 5(a)(1) of the OSHA Act requires:
“Each employer shall furnish to each of his employees, employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

In other words, the GDC is the “gap filler” used to address hazards that OSHA has not yet regulated.

THE MOVIE ANIMAL HOUSE, OSHA AND YOU

As a quick aside, one of my favorite movies is the 70's classic "Animal House." At the risk of you missing the perfect metaphor for the General Duty Clause, take a look at this 2:16 clip from “Animal House” on YouTube: 

So now you might be asking, how are OSHA and Double Secret Probation relevant to me? Let me give you an example. 

My professional world is cranes, specifically EOT (electric overhead traveling cranes). Safety regs for EOT cranes are covered by OSHA 1910.179. Section 179 is a little under 7000 words and most crane owners make, the not unreasonable assumption, that if they comply with 179 they've done their job. This is a reasonable but dangerous assumption and here’s why.

DOUBLE SECRET PROBATION, PHASE I

The General Industry 1910 OSHA specs includes the paragraph 1910.6, entitled  “Incorporation by Reference.” With this paragraph, OSHA includes just about all the “national consensus standards" you can think of. The “national consensus standards” are those many standards that have been issued over the years by such groups as ANSI (American National Standards Institute), ASME (American Society of Mechanical Engineers), NFPA (National Fire Prevention Association), etc. 

Actually, OSHA paragraph 1910.6 incorporates over 200 national consensus standards. This means that each one of these 200+ specifications have the full weight of law, just as if directly written into the OSHA pages!

Yes, I admit I have taken a bit of literary license claiming the 1910.6 is Double Secret Probation because OSHA has in fact said, in plain english, that all the referenced specs in 1910.6 paragraphs have been incorporated into OSHA.

Who has the time to peruse 1000 pages to find this obscure paragraph? Any busy professional will do a search for their relevant section and then dissect that section. They’ll not read all 1000 pages in search of a “gotcha paragraph, and it’s absurd to assume they will. What these lawmakers failed to realize is that we don’t have a congressional staff, paid by taxpayer funds, to do our reading for us.  In other words, this obscure but crucial paragraph (1910.6) should, at the very least, be foot-noted at the bottom of every section like 1910.179.

DOUBLE SECRET PROBATION, PHASE II (the nuclear phase)

The nuclear phase of Double Secret Probation is GDC or the General Duty Clause. This is the paragraph that basically says that everything not specifically included in the other 1000 pages is covered under the General Duty Clause. In other words, a crane owner can't feel safe having diligently met all the requirements of 1910.179, they are still "as naked as a J-bird" from the perspective of the GDC.

EXACTLY WHAT IS THE GENERAL DUTY CLAUSE?
The General Duty Clause, Section 5(a)(1) of the 1970 law, requires employers to maintain a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm" to employees. Pretty simple statement isn’t it? What ethical person could argue with the intent of this simple sentence?

The law itself doesn't actually define any hazards or set any specific safety standards. Instead, it gives OSHA, acting on behalf of the U.S. Secretary of Labor, the authority to formulate national standards and enter them into  Federal Regulations. 

CATCH 22, ANOTHER HOLLYWOOD BUSINESS LESSON

At the risk of mixing my movie metaphors, the scary part of the GDC is it's "Catch 22'ness.” In the movie Catch 22, a soldier could get out of combat if they could prove they were insane, but the mere act of wanting to get out of combat was certification of normalcy and therefore the soldier was promptly sent back into combat.

So how is GDC a Catch 22? A good example is that OSHA doesn't require EOT crane conduct bars to be insulator covered. In other words, old fashion bare copper wire conductors carrying 480 volts is legit. 

Now here's the rub. What happens when a worker, is above floor level (changing light bulbs, fixing a sprinkler line, etc.) and is electrocuted by coming in contact with the exposed bare wire? 

By definition, isn't every fatality a person that was exposed to “a danger?” If there wasn't a danger, how did they die, and if there was a danger, did the employer fail to fulfill their GDC duty? Like I said earlier, although well meaning in it's intent, GDC is the "Catch 22" of employer liability.

IT'S BAD, BUT NOT QUITE THAT BAD

Before you jump off a tall building, let me talk you off the ledge. There are precautions you can take to guard yourself from both Double Secret Probation and Catch 22. 

Although not included in the OSHA 1910 code, the courts have decided that there are four specific conditions that must be present to be considered guilty of a GDC infraction. ALL four factors must be present.

THE FOUR PREREQUISITES OF A GDC INFRACTION
1. The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed.
2. The hazard was recognized.
3. The hazard was causing or was likely to cause death or serious physical harm.
4. There was a feasible and useful method to correct the hazard.

Remember,  all four factors must be present for a valid GDC infraction. These four factors are usually found by forensic investigators in your paper trail.

KNOW YOUR PAPER TRAIL

In this computer age, it seems like our paper trail is more ephemeral than ever, but in reality, it's just the opposite. Even though it’s painfully easy to delete files and no matter how carefully you follow a naming convention, you can never find that one document you created last summer, it's out there. It’s either somewhere on your computer, the company server, a backup system, in somebody else's email box or in “the Cloud,” but rest assured, it’s out there somewhere. A forensic computer expert can find just about anything, even files you specifically took pains to delete from your computer.

Please be aware, this is not a “nod and a wink” to purging your digital world of potentially harmful documents. This is not a moral judgement, but rather a fact. In todays digital world, it just can’t be done!

So what are these paper trail sources?

Internal Documents;
1. Maintenance records of previous repairs
2. Safety audits
3. Internal emails
4. Internal text messages
5. Company work rules
6. SOP docs
7. Collective bargaining agreements
8. Prior incident records
9. Past near misses
10. Injury reports
11. Workmen's comp claims
12. Insurance claims

Other sources include;
1. Industry recognition of related issues
2. Insurance industry recognition of related issues
3. Manufacturer’s equipment owners manuals
4. National consensus standards

Bottom-line, is that the “Three Monkey Defense” of hear no evil, see no evil and speak no evil "ain't gonna cut it." To claim you weren't aware of the hazard in you own building is going to leave a gap in your legal protection that both OSHA and the Plaintiff's lawyer will be able to drive a semi-truck through.

FURTHER LEGAL EXPOSURE OF A GDC VIOLATION

We're not talking nickels and dimes here. A GDC violation has a $7,000 price tag and if the violation is deemed willful or a repeat violation, the penalty goes from $7,000 to $70,000! But $70k is chump change compared to the real danger.

The real danger of incurring a GDC violation is that it can be construed as an admission of negligence for both worker's comp and personal injury/wrongful death tort litigation.  Some states even allow exception to “Workers Comp exclusivity” if gross (willful) negligence is involved. 

GDC AFFIRMATIVE DEFENSES

Because of the legal exposure of a GDC violation, these violations can’t be taken sitting down. So what’s the best defense? The best defense is a pre-violation offensive move. You must prepare for the violation before the accident. Pursue a “Prudent Man” policy. A Prudent Man policy means taking the necessary steps to make sure at least one or more of the required four prerequisites cannot be established. 

In my view, items two and three are the most important factors.
Item #2: The hazard was recognized
Item #3: The hazard was causing or was likely to cause death or serious physical harm

To establish a case for either or both of these issues, a hazard must be identified, accommodated, properly documented and then periodically audited for effectiveness and continued compliance.

CERTIFIED INSPECTION

At it's core, OSHA is a basically like a pilots “pre-flight inspection program” with an established paper trail to document the inspection and the remediation. Inspections can be divided into three groups;
1. In-House Inspections
2. Third-Party, Equipment Manufacturer’s Inspection
3. Certified, Third-Party Independent Inspectors

1. In-House Inspections
In all but the largest companies (with dedicated inspection crews), in-house inspection is usually a hit or miss affair. It's usually performed by the maintenance guys at the bottom of the seniority list (the experienced guys are busy fixing something) and the position involves little "book" training of the requirements of the applicable codes. Truth be known, it's usually a case of "pencil wiping" a checklist.

The most damning aspect of in-house inspectors is not periodically getting a new pair of experienced eyes to help discover the potential problems. These in-house inspectors see these same problems day after day, much like the broken switch plate in your kitchen at home. After a long enough period, you no longer see the broken plate and it never get’s replaced until you sell the house.

2. Third-Party, Equipment Manufacturer’s Inspection
This represent a big step forward by hiring a firm that employees professional inspectors. The critical problem here is that the firm is a division of an equipment builder. 

Beware of companies that offer "bait and switch" inspections for absurdly low prices. The gambit is to "get in the door" charging next to nothing for the inspections on the front end, only to make up for the loss by charging excessive amounts for un-needed repairs or better yet, a replacement crane.

 Getting the big picture of the vendors business model is always a good place to start your evaluation. Like always, beware of deals that are "too good to be true," because they probably are.

3. Certified, Third-Party Independent Inspectors
A worthy third-party inspection firm needs to encompass five characteristics. 
A) Documented experience in the field. 
B) A standardized documentation system/paper trail.
C) Documentation showing continued pursuit of industry education.
D) Proof of Errors and Omissions Insurance.
E) A reasonable pricing structure that can sustain a professional/competent consultant.

The choosing of a third-party, professional inspection company is the center-piece of your GDC Affirmative Defense. Engaging a third rate inspection firm for a price that's “too good to be true” is a dead give-away on how you value safety. The hiring of an unreasonably cheap inspection firm can result in a case being made that your safety program is just "window dressing." 

The hiring of a quality Certified, Third-Party Independent Inspectors is the centerpiece of your “Prudent Man” defense. Engaging a professional inspection firm with impeccable credentials (copies of which must me kept on file) is all the court can expect a “Prudent Man" to do and will just crush the soul of the Plaintiff's lawyer (assuming they have a soul).

AN AFFORDABLE AND PRACTICAL, CYA INSPECTION PROGRAM

In this era of getting clicks with alarmist headline, I not only want to warn you of a threat, but to also offer a blueprint for a program that will both maximize worker safety while providing a good dose of CYA, all for an affordable price.

An ideal program that maximizes effectiveness while minimizing costs is a combination using both In-House inspections with Certified, Third-Party Independent Inspectors. The program should look something like this;
1. Annual Inspections Hire well documented, Certified, Third-Party Independent Inspectors for the annual inspections. Use the inspector’s documentation forms if at all possible because they’ve already fought the internal tug of war between being complete while at the same time not pricing themselves out of the market. Besides, they’re the experts and they know better than you the required paper trail.
2. Interim Inspections In the case of EOT cranes, in addition to the annual inspections, OSHA requires daily and what they term "periodic" inspections (may be weekly, monthly or quarterly), based on equipment duty cycle. These interim inspection can be performed by In-House Inspectors. Use the Inspection Firm as a consultant for determining the frequency required, the establishment of a paper trail and the training of the In-House inspection staff. This will be a one time cost and again, in the face of a possible legal issue, you can say you deferred to the guidelines of “an expert.” for both training and documentations. 
3. Interim Inspection Audits At the time of the annual inspections, have the independent inspection company perform a cursory audit of the paperwork performed by the In-House inspection staff. Use this time as learning experience for the In-House crew, both on their paperworks as well as a Q&A session on their inspection technique. This whole process should be accomplished in an hour or so and done annually at the time of the annual inspection.

SUMMARY

The reality of doing business in the first quarter of the 21st Century is that we live in a litigious world, which is news to nobody. The real news is that a GDC violation can very easily devolve into a disastrous domino effect and the GDC infraction may be the least costly problem of the event.

More dangerous than OSHA are the other members of this crew of hanging judges. This group can include a plaintiff’s lawyer, workmen's comp multipliers, health insurance costs and cancellation of insurance carriers coverage.

Never has it been more important to boldly set claim to an unquestioned position as a “Prudent Man” when it comes to safety, and the best way to claim this space is the hiring of a professional Certified Inspector. 

The pleasant dividend of this pursuit of a “Prudent Man” policy is that it cannot help but to produce a safer workplace and therefore lower Workman’s Comp costs, lower health care costs, lower lost time accidents and drastically lower expenditures for legal fees.

If there ever was a doubt in your mind that safety pays, it's time to become a true believer.

State Vs. Federal OSHA Codes

 States with non-Federal Plans in Blue and Gray

States with non-Federal Plans in Blue and Gray

There Are Actually over Two Dozen OSHA's

Surprise!!! OSHA is not just one entity, it’s in fact a couple dozen. This makes it really tough for manufacturers of Overhead Industrial Cranes. When Congress passed OSHA in 1971, it yielded to what I suspect was the typical fight between Federal and State Rights advocates.

OSHA was passed while I was in high school. I didn’t really pay attention to those type of things as an 18 year old.  States Rights vs. Federal control has been an issue since Thomas Jefferson and Alexander Hamilton, I suspect it was an issue in the passing of the OSHA legislation too.

Who's In Charge Here?

The long and short of it is, the Federal law allow for states to pass their own versions of OSHA, provided the states’ version was equal to or greater than that of the federal statute. 

The really confusing thing is that some states passed a far more stringent and complex versions (like Michigan, Oregon, Washington and California) and some states passed a virtual duplicate of the federal statute ( like Indiana, Illinois and New York). My puzzlement is in the fact that so many states passed near duplicates of the federal statute.  Why? My only guess is that it further swelled the ranks of state appointed positions and therefore provided governors’ with more appointed positions, as a form of payola to party loyalists.

Writing the Governor

As a quick aside, I once incurred a violation for not having a hand-railing on three steps up to a job site field trailer. I was young and naive at the time and told my foremen to remedy the situation immediately. As the inspection wrapped up I pointed out to the inspector that the hand rail was already in place. The inspector nodded and smiled.

A couple weeks later I received a an official looking document from the state. In the document it listed the stair hand railing as a violation with a fine of $500 (I think that was the number, it’s been 20+ years). I immediately call the OSHA office in Indianapolis and politely complained. I was told my rectification of the problem has no bearing on the violation. 

At this point I blew a gasket. I said they needed to tell me the purpose of the OSHA code. Was I mistaken that it’s purpose was to make the workplace safer? If the code was to be a revenue source, just tell me and I’ll send in my money, but at least be honest and call it a tax and not a safety code. 

Immediately after hanging up the phone, I wrote the governor of Indiana and  told him my story.

About a week later I received a call for the Director of Indiana OSHA. Here’s how the conversation went;

OSHA Director:
Are you the Larry Dunville that wrote the governor about an OSHA violation. 
Me:
Yes. 

OSHA Director:
You need to understand, you shouldn’t write the governor, you should write me.
Me:
Frankly, I was mad and my question was about the very purpose of the OSHA law.

OSHA Director:
Don’t write the governor.
Me:
The OSHA law should be to make workers safer.

OSHA Director:
Mr. Dunville, you're not listening. Don’t write the governor.
Me:
But I had remedied the problem before the inspector had even left the site.

OSHA Director:
Don’t write the governor.
Me:
Will I get relief on my infraction because the problem was immediately remedied?

OSHA Director:
No and don’t ever write the governor again. 

End of call.

Life Lesson

If you really want OSHA’s attention in a state administered OSHA plan, write the governor. You won’t get your money back, but it gives you a great deal of satisfaction getting the state director in hot water with his boss!

Reference Paper

For a summary on all the state OSHA plans, click below. The paper was written in August of 2016 and is to the best of my knowledge current, but if you have any detailed questions about a particular states safety codes, make sure to directly contact the appropriate state occupational safety website. Contact information for all the state programs is included in the downloadable PDF file.

Down loadable State OSHA Plans Summary PDF.

OSHA 1910 Decoded

The number one rule to understanding OSHA is to understand that it’s not just the OSHA 1910 document. Because of three words, OSHA is not just a single document but rather hundreds of documents and thousands of pages.

Incorporation By Reference

Three simple words, “Incorporation by reference” opens the flood gates. It means the 11 pages of “Overhead and Gantry Cranes” is only the tip of the iceberg. 

ANSI/ASME B30.2

OSHA 1910.179 specifically references a dozen document, but it is influenced primarily by one document, ANSI/ASME B30.2: Overhead and Gantry Cranes, (Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoists) and secondarily by a whole host of specifications.

OSHA 1910.179 Overhead and Gantry Cranes

So we must get started somewhere and it makes sense to start with the “mother” document, OSHA 1910.179 Overhead and Gantry Cranes. Let’s tear the Crane section apart, paragraph by paragraph.

Forensic Expert Witness

The OSHA 1910 is the touchstone reference document for the Forensic Expert Witness as well as the Plant Engineer.

Click here to download PDF version

OSHA: The 1971 Lawyer's Full Employment Act

Incorporated by Reference

 Three words that can turn your world upside down

When I first received a printed, bound version of OSHA 1910, I sunk in my chair at the assignment of having to get command of this document. It became my responsibility because I was the new kid at work, with a freshly minted college degree and a customer list of zero. The OSHA book was considerably larger than the South Bend, Indiana phone book, with fine print to match. 

After leafing through the book, I found the crane section 1910.179. Much to my relief, OSHA 1910.179 was about 11 type written pages long, about 7300 words. I thought confidently that I ought to be able to knock it out by lunch. 

In spite of the "legalese,” tortured sentences and frequent circuitous logic, by lunch I told my Dad that I was "on top of it." Little did I know what I didn't know. The eleven pages from 1910 were only the tip of the iceberg. Some time later I was reading a trade journal and came across an article on "Incorporation by Reference.” Upon completion of reading that article, my life became absurdly more complicated.

“Incorporation by reference is the act of including a second document within another document by only mentioning the second document. This act, if properly done, makes the entire second document a part of the main document.” 
Wikipedia

Russian Matryoshka Dolls

In the future, I’ll periodically refer to this as the “Russian Matryoshka Doll Inversion.” I call it that because on one hand, like Russian Matryoshka dolls, seemingly every document has one or more documents buried inside the current document. But unlike the Matryoshka doll, frequently the referenced document buried inside the current

document is far, far larger than the initial document.

In addition to the “Matryoshka Doll Inversion” is the “Family Tree Syndrome.” This is when the first document is referenced to five, second  tier documents, which are then each referenced to eight third tier documents, and on, and on and on. The final number of pages is probably near infinite. That’s just a guess because I’m sure nobody has lived long enough to list all the incorporated documents, much less counted the pages. 

These Specs Cost Big Money!

By the way, the OSHA documents are free, public domain documents (if you get an on-line PDF version), but all the other documents are copyrighted and privately owned by the likes of ANSI, ASME, CMAA, etc. Each of these document cost between $50 and $400 dollars for a simple PDF copy. To make a bad situation worse, they are all revised every couple of years, usually 90% unchanged. The problem is that you won’t know what parts have been changed until you buy the new version.

Here's the List

Well, so much for my rant. You would have thought the “On-Line, Information Age” would have decimated this ridiculous system, but it hasn’t. So here’s a link to Section 1910.6 Incorporation by Reference from the current (2016) version of OSHA 1910 spec. It lists over 200 additional specifications Incorporated by Reference thereby making all these additional specs part of the OSHA 1910 specification.

By the way, regarding cranes specifically, 1910.6 incorporates by reference ANSI/ASME B30.2 which references CMAA 70, which in-turn referenced 24 other specs including AWS, AGMA, NEC, etc.

Although the acronym OSHA stands for Occupational Safety and Health Administration, with an infinite number of documents “incorporated by reference” it more accurately should have been called The Lawyers Full Employment Act of 1971.

A Custom (air tight) Purchasing Specification

Most of you that read these posts are probably aware that, in addition to consulting work on overhead cranes and crane runways, I also do a considerable amount of work as an Expert Witness for legal cases involving cranes. As a result, my recreational reading is often hijacked by the latest edition of specs related to overhead cranes. Besides, reading spec books is a wonderful, drug free, solution for periodic insomnia. 

2015 Editions of the CMAA Specs

Last weekend I read the latest (2015 editions) of CMAA Spec 70 and CMAA Spec 74. After a lifetime in the crane business, I've paged through these specs a thousand times, but can't remember the last time I sat down and read them from cover to cover. The 2015 editions of Spec 70/74 seem to have more new material and changes than any revisions in recent memory. I decided to read them from front to back. Needless to say, my weekend was peppered with a number of involuntary naps.

Reading the Fine Print

I'm in the process of writing a comprehensive outline of both specs. Before diving into the outline, I felt compelled to write a post about something that I found that really surprised me, something I never read before. I was nearly knocked out of my reading chair on page 2 of the spec.

What could be such a shocking fact, found so early in the document? My "shock and awe" moment was the "Disclaimers and Indemnity" page. (FYI, for this post, I'll use CMAA Spec 70 (2015), but it is essentially the same as CMAA Spec 74). Let’s take this page apart, section by section.

Page 2, Section 2 Specifications, Paragraph 1:

“Users of these Specifications must rely on their own engineers/designers or a manufacturer representative to specify or design applications or uses. These Specifications are offered as information and guidelines which a user may or may not choose to adopt, modify or reject. If a user refers to, or otherwise employs, all or any part of these Specifications, the user is agreeing to the following terms of indemnity, warranty disclaimer, and disclaimer of liability”.

This paragraph is no surprise, a typical CYA paragraph.

Page 2, Section 2 Specifications, Paragraph 2:

“The use of these Specifications is permissive and advisory only and not mandatory. Voluntary use is within the control and discretion of the user and is not intended to, and does not in any way limit the ingenuity, responsibility or prerogative of individual manufacturers to design or produce electric overhead traveling cranes which do not comply with these Specifications. CMAA has no legal authority to require or enforce compliance with these Specifications. These advisory Specifications provide technical guidelines for the user to specify his application. Following these Specifications does not assure his compliance with applicable federal, state, and local laws or regulations and codes. These Specifications are not binding on any person and do not have the effect of law”.

1) Sentence one should not be a surprise. The CMAA is an industry association and not a governmental agency. It therefore has no legal authority. Conversely, it is the defacto standard of the industry, therefore carries a considerable about of weight but not a legal mandate.

2) Sentence two does not preclude anyone from building, selling or using a crane that does not conform to the spec.

3) Sentence three simply confirms that CMAA has no legal authority.

4) Sentence four reinforces that this spec is simply a "guideline". 

5) Sentence five protects the association from having to research state laws and/or a wing-nut interpretation by some local inspector or court.

6) Sentence six, reiterates that these specs are not binding and do not have the force of law.

Page 2, Section 2 Specifications, Paragraph 3:

“CMAA and MHI do not approve, rate, or endorse these Specifications. They do not take any position regarding any patent rights or copyrights which could be asserted with regard to these Specifications and do not undertake to ensure anyone using these Specifications against liability for infringement of any applicable Letters Patent, copyright liability, nor assume any such liability. Users of these Specifications are expressly advised that determination of the validity of any such copyrights, patent rights, and the risk of infringement of such rights is entirely their own responsibility”.

Everything after the first sentence are reasonable CYA sentences, but sentence #1 knocked me for a loop! 

"CMAA and MHI (the parent organization) do not approve, rate, or endorse these Specifications”.

What in the hell does it mean not to "approve, rate or endorse" your own specification? To have spent thousands of dollars (probably tens of thousands) and have the best and most experienced minds in the industry write two 100+ page specifications and then not to "approve, rate or endorse" them is the essence of “theatre of the absurd.” I'm sure, for some reason the legal counsel advised the CMAA/MHI to add this sentence, but it's indicative of a system that I'm embarrassed to be part of. 

Page 2, Section 2-Specifications, Paragraph 4:

“Caution must be exercised when relying upon other specifications and codes developed by other bodies and incorporated by reference herein since such material may be modified or amended from time to time subsequent to the printing of this edition. CMAA bears no responsibility for such material other than to refer to it and incorporate it by reference at the time of the initial publication of this edition”.

This is an important paragraph. The paragraph introduces a concept that's critical for the reader to be aware of. The term "incorporated by reference" is the ultimate spec writers ”gotcha."  CMAA 70 incorporates by reference over 25 other specs such as AWS 14.1, the National Electric Code and OSHA 29CFR Part 1910. Those three alone comprise a couple thousand sopoforic pages. (Author's note, I've waited over 30 years to use that word, it means, tending to induce drowsiness or sleep. Dad and Mom, that Notre Dame education paid off!)

Conclusion:

So what's the point of the previous 997 words? Beside a rant against a broken legal system, it gets back to Caveat Emptor. Let the buyer beware. If the CMAA specs don't have the force of a legal mandate then the buyer has to protect themselves through writing a comprehensive specification of their own. It’s not good enough to simply say, “…I want a 30 ton, CMAA Class D Crane”. The buyer must specifically include the sellers must fully conform to CMAA Spec 70/74 as a requirement of the contract, and that’s just the beginning.

Additional questions include (but are not limited to)

Crane configuration:

  • Top running
  • Under running
  • Wideflange or Box Girders
  • Drive configuration
  • Cab or no-cab operation
  • Pendant or radio
  • Inverter control
  • Travel and lifting speeds
  • CMAA Duty Rating

Crane clearance:

  • Below the hook
  • Above the crane
  • Above the runway
  • Runways by who
  • Runway girders
  • Runway rail
  • Runway rail fasteners
  • Runway rail alignment
  • Runway conductor supply
  • Runway conductor installation
  • Runway power source 
  • Runway supports
  • Supports configuration
  • Supports supplied by
  • Supports installed by

Specifications:

  • CMAA
  • HMI
  • OSHA
  • ANSI
  • ASME
  • NEMA
  • AWS
  • NEC
  • Etc.

Misc:

  • Approval process and prints required
  • Delivery Schedule
  • On-site storage/staging area
  • Unions/Non-union Installation Crews
  • Field measurements

If you don’t specifically address these points (and still others), there’s a good chance that an additional cost of your project will be legal fees, and those fees can approach the cost of the cranes!    

The Second Most Important Spec to Include:

One last note, the CMAA is really a crane spec and not a hoist spec. Hoist builders are not necessarily members of the CMAA. Hoists builders are members of HMI, the Hoist Manufacturers Institute. Their specs are ASME/HMI HST-1, ASME/HMI HST-2, ASME/HMI HST-3, ASME/HMI HST-4 and ASME/HMI HST-5. We'll go into the HST specs later.

 

 

Tips, Tricks and Traps of Crane Contracts

IT'S NOT ROCKET SCIENCE, BUT...

I’ve had everything from hundred page specs (you guessed it, US Gov’t specs)  for a $5K jib crane to single page page specs for a million dollar system. One thing  I’ve learned is that there is no relationship between the number of words and the quality of the specification. 

Having been around long enough to have seen both the “pre-word processing” era and “post-word processing” era, buying documents have not got any better, just considerably fatter.

WHO NEEDS THIS MUCH DETAIL?

There are a lot of crane buyers that don’t need this hours and hours of information included in this article. Fact of the mater is, if they’re buying an average system, that is average duty cycle, average project size, average environment, average lift height, average production through-put, this article is probably overkill. 

SPECIAL SITUATIONS

If your planning a purchase that includes one or more of the following characteristics, skip this article at your own peril.

  1. Multiple cranes, big dollar deal
  2. High duty cycle crane applications
  3. High speed crane applications
  4. Long lift crane applications
  5. High production through-put applications
  6. Mission critical applications
  7. Explosive atmosphere
  8. Abrasive atmosphere
  9. Hot metal handling
  10. Nuclear anything
  11. Extremely hot or cold environment
  12. Critical timeline delivery requirements
  13. Precise spotting control
  14. Automated controls
  15. New cranes on existing runways or runways not supplied by the crane builder
  16. High (crane/hoist) motor starts per hour
  17. Low (crane/hoist) motor idle time per hour
  18. High average percentage of capacity load per lift
  19. Magnet applications
  20. Coil handling applications
  21. New building construction project
  22. Applications requiring true vertical lift
  23. Applications that require full capacity lift 100% of the time
  24. Precision spotting lifts that require Inverter controls
  25. Applications with dirty power sources and/or voltage swings
  26. Plus any other out of the ordinary application

I don’t mean to imply that Cranes are rocket science. They’re not, but conversely many buyers think all they need to tell a crane vendor is that they need five ton capacity and to “fit it in there,” and they’re done. That attitude may work on the very simplest applications, but for most it’s a formula for disaster.

For the next four articles, we will divide the crane buying process into four parts.
1. Buyers RFQ
2. Sellers Proposal
3. Contract/PO
4. Misc Items

Lift, Hook Height or Crane Clearance???

Hook Height – Vertical Clearance -- Lift, 
Aren’t they all the Same?
 

 
NO! They each have significantly different meaning and to use the wrong one, as is frequently done, can have disastrous consequences.

 
A. Crane Clearance

This can be measured in a number of ways so make sure your using the right term for the dimension you require.

  1. Clearance from floor to the lowest building obstruction
  2. Clearance from the floor to the bottom of the crane girder
  3. Clearance from the floor to the hook
  4. Even floor to the bottom of the runway 

B. Height of Lift or Hook Height

The distance from the floor to the crane hook in the highest position. This dimension is critical in most applications as it determines the height of the runway from the floor and is dependent on the inside height of the building. On a Double Girder crane, the hook can withdraw in between the girder (see figure 2 below). This may not be usable space, depending on the size of the object you lifting. 

3. Hoist Lift

Hoists come in incremental drum lengths. You may require only 20 ft of lift, but the drum may have 28 ft of wire rope on the drum. Don’t be confused by a vendor quote regarding the term “Lift”. Make sure you ask for both numbers and make sure if the hoist has more rope then necessary, that the hoist is equipped with a lower limit switch. This will prevent the hook from hitting the floor and unraveling the remaining rope off the drum.

 

Recap:

1. Hoist lift dimension

The hook up dimension and the available rope on the drum are two different measurements.  Make sure you know which one is being quoted.

2. The Vertical Measurement has 4 different factors

a. Floor to bottom of girder
b. Floor to hook
c. Floor to top of runway
d. Floor to lowest overhead obstruction

3. Pay special attention to the configuration of the crane to make sure your dimensional assumptions are appropriate.

Probably the best tool to avoid confusion is simple line drawings. The old saying a picture is worth a thousand words is never more accurate than in this circumstance.

Martin's Ring-binder Notebook

INSTITUTIONAL KNOWLEDGE

Shortly after I graduated from Notre Dame, I started with my family company, Dearborn Crane. During high school and college summers, I had worked in the shop building cranes and then progressed to the field crew, installing cranes. During school holidays like Christmas and Spring Break I’d do odd jobs and do “gofer” stuff, picking up and dropping off pieces and parts to earn some pocket money. 

After graduation, I had no projects, because I was the new guy and could feel the gravitational pull of the “gofer” work to fill my days. I approached my Dad and he promised to take me on the next big project to work with him. Shortly, we were on our way to AM General (the manufacturer’s of the Hum-Vee). 

THE FIRST BIG PROJECT

We attended a bidders meeting where the buyer’s Project Engineer and Purchasing Agent issue a spec book and walk a group of vendors through the up-coming project. At the end, we were told we had two weeks to estimate the project and submit a “sealed bid.”

Back at our office, my Dad told me to work on the project my own and two days before the bid due date, we would compare numbers and I could write up the proposal.

THE ESTIMATE

For the next two weeks, I worked 10 hours a day, including Saturday and used three legal pads (this was before desk top computers and spread sheets). I sat down with other engineers and called a list of vendors. 

After two weeks of effort and a whole roll of adding machine tape, I finally settled on a price. For some reason, I can remember that price like it was yesterday, $89,271.32 (probably about $890K in 2016 dollars).

On the Wednesday before the Friday bid due date, my Dad and I sat down to review our numbers. I brought an arm full of catalogs and my three legal pads into his conference room. He brought nothing. I asked him where  his estimate was? He took out a matchbook and wrote a number on the back of it and put it in his shirt pocket. He then said, now let’s look at your numbers.

THE LONG VERSION VS. THE SHORT VERSION

We spent over an hour and I showed him all my worksheets. Vendor prices, additional discounts that the other engineers told me to get from the vendors. I even included the “cost of money” in an attempt to prove his four years of Notre Dame education was money well spent.

At the end of the review, I showed him my $89,271.32 and asked him what number he had come up with. He took the matchbook out of his shirt pocket and flipped it over. His number was $90,000.00!

THERE’S GOT TO BE A BETTER WAY

I was happy my number was close, proud of the results but frustrated. I said “Dad, why did I just spend 100 hours doing this? How did you come up with that number in ten minutes???” He said he’d been doing this for over 40 years and if he didn’t know this by now, he might as well hang up his cleats.

After mulling over his answer, I said, “ Dad, we have to come up with a better system. We can’t have a 40 year training program to train me and future estimators.”

MARTIN’S FOUR INCH RING-BINDER

After hearing this story, my Uncle Martin Dunville (who started the company with my father) started putting together a ring binder with all the disparate cheat sheets he had accumulated over the years. Within a month, Martin gave me a 4 inch ring binder so stuffed with information that I could barely close it.

A 21ST CENTURY FOUR INCH RING-BINDER

Last week I sat down to make a “mind-map” of “Tips, Tricks and Traps” of 35+ years of overhead crane knowledge. Half way through, it dawned on me that I was composing a new version of Martin’s Ring-binder. 

What started out as a simple map exploded in size and complexity, and this is only Version 1. I’ve decided that the document in it’s current iteration is too big to explain. In future posts, I will break it down, and explain one branch at a time.

Hook Coverage, What is it and Why is it Important?

Overhead Crane Hook Coverage

If the purpose of your new crane is to provide max storage of say, steel coils in your warehouse or maybe you need to lift something on the edges of your building, be careful. The physical dimensions of the cranes' mechanical components provide constraints that are expensive if not impossible to overcome.

Side Approach

 End view of bridge crane looking down runway.

End view of bridge crane looking down runway.

The "Side Approach" is that lateral dimension, the left to right movement of the trolley hoist. It's a measurement of how close to the side walls you will be able to get your hook. Even without any other obstructions like building knee braces, roof drains or heaters, the physical width (wheelbase plus overhang) of the hoist and trolley will be a dimensions constraint that's hard if not impossible to overcome. 

Application Tricks Available

  1. Hoist are not symmetrical (usually), so there will be a short side and a long side.
  2. Different brands have different side approach dimensions, so shop around.
  3. The wire rope drum orientation can be perpendicular or parallel to the bridge girder. Therefore, long lift applications would be helped by a perpendicular drum orientation.
  4. Chain hoists, because they don't need a drum, frequently provide better end approach. Note that chain hoists are usually suited to, at best, moderate duty cycle applications and usually under 10 ton capacity.

End Approach

 End view of end truck, showing wheelbase of crane and end view of double girder hoist.

End view of end truck, showing wheelbase of crane and end view of double girder hoist.

Where the Side Approach dimension is governed by the width of the trolley/hoist, End Approach is a longitudinal dimension and dictated by the overall length of the end truck. Again, due to things like electrification and walkways, this dimension is not necessarily equal on both sides of the crane. 

Application Tricks Available

  1. Although end trucks are normally symmetrical, the crane layout may not be. Considerations like walkways, line shaft bridge drives and festoon conductors, can provide a dimensional advantage to rotate the crane for better end approach.
  2. A specially designed, "spacer saver" end stop can sometimes save over a foot, but are more expensive.
  3. A runway dog-house in which the runway protrudes through the end wall, thereby allowing part of the end-truck to extend beyond the end of the building has been used in extreme cases. It's called a "dog-house" because from the outside of the building is looks like two dog-house sized appendages will be sticking out of your building. The worst case scenario is if the dimension problem is your fault, from that day forward, these two warts sticking out of the end wall of your building may be called "Bill's Memorial Doghouse." And if you're really unlucky, the maintenance crew will put a sign on both sides, emblazoned with your name. In spite of the looks, the concept works and might just save your bacon.
Any resemblance to persons living or dead should be plainly apparent to them and those who know them. All events described herein actually happened, though on occasion the author has taken certain, very small, liberties.

Note; if you choose to rotate the crane 180 degrees to gain end approach on one end of the building, your conductor bar will now be on the wrong side to feed the crane. If the runway has not yet been installed this is easy. If the runway has been installed or it would be too costly to feed the power from the other runway, conduit can be run from the formerly powered side of the crane to the opposite side in a pinch.

 

 

The Mandated Crane Overload

Yes... When Overloading a Crane is Required

The recent few Crane College articles have delved into issues surrounding Bridge Crane Capacity. More specifically we’ve reviewed the “Rated Capacity,” that is, the maximum legitimate lift. We’ve looked into the concept of engineering “safety factors,” and how crane end users SHALL NOT  encroach into these safety factors.

 

Who’s the Boss Here?


As a quick aside, it’s important to understand who makes the rules that cover these situations. Unfortunately, industrial safety policies are covered by a multitude of specifications, CMAA, HMI, ANSI, and OSHA to just name a few. Through the concept of “incorporation by reference” there are literally hundreds of documents in the mix. The CMAA Spec 70 alone incorporates over two dozen references in just the opening pages of the spec. The CMAA incorporates things like AWS spec for welding, ASME spec for bolts and fasteners, and someone else for paints and coatings.

For the purposes of this topic, I have chosen to use two of the primary level specifications, ANSI (The American National Standards Institute) and the OSHA 1910 specs. These are US specs and I’m not sure the extent to which other countries adopt these policies.

Most recently, I wrote about the two circumstances in which purposely overloading a crane is acceptable.
1. Planned Engineered Lift
2. The initial crane system load test

 

PLANNED ENGINEERED LIFTS 


The Planned Engineered Lift is both “Planned” and “Engineered.” It is a logical and systematic process by which engineers are called in to check all twelve of the links in the chain of the lift. Most cranes will never be exposed to this process, which means that Crane College paper of mine would be a good one to file away somewhere, on the “oft chance” that some day you just might need to execute a “Planned Engineered Lift.”

 

INITIAL SYSTEM LOAD TEST


Where the Planned Engineered Lift is a “someday/maybe” possibility, the Initial Crane System Load Test is a mandated, day one requirement. 

OSHA 1910.179 Paragraph K2 states the following;
 Rated load test.
Test loads shall not be more than 125% of the rated load unless otherwise recommended by the manufacturer.  The test reports shall be placed on file where readily available to appointed personnel.

 

ANSI B30.11 requires the following;
11-2.2.2 Rated Load Test
(a) Prior to initial use, all new, extensively repaired, and altered equipment shall be tested and inspected by, or under the direction of, an appointed or authorized person, and a written report should be furnished by such person, confirming the load rating of the system.  The load rating should no be more than 80% of the maximum load sustained during the test.

Example: 
100 Ton Rated Capacity new crane
100/0.80= 125 Tons test weight required to perform load testing


IMPORTANT NOTE: This will require that the hoist overload protection system be temporarily bypassed for the duration of the test. I have personally performed these tests and even gone to the precaution of looping my car keys on the bypass jumper wire in the crane control panel, to make sure I couldn’t drive away without removing the bypass wire and therefore reinstating the overload protection system.

 

Warning Regarding ANSI Interpretation


Over the years, I have ran into a number of projects in which the buyer would question my including a line item price for the load testing. The buyer would say that my competitor didn’t include load testing because they said that all hoists had to be load tested at the manufacturers factory. 

The first time I heard this objection, I thought we might might be wrong. I went back our office and combed ANSI, ASME, CMAA and HMI. After carefully parsing the words I zeroed in on the phrase “confirming the load rating of the **system**.” In other words, you have to check the viability of not just the hoist, but also the entire structure holding the load. This chain of interconnected structures includes;

  1. Hoist
  2. Hoist trolley
  3. Bridge girder
  4. Bridge girder connection
  5. End trucks
  6. Crane rails
  7. Crane support beams
  8. Crane support columns and/or building columns
  9. Support column footings

The only way to “confirm the load rating of the system” is to load test the installed and completed crane "in place" thereby also load testing the runways, columns and support structure too.

 

Separating the Men from the Boys


As a good test of crane knowledge, I would suggest buyers ask what procedure their prospective bidders have regarding the Load Testing of their crane. They should be able to answer, a) is load testing required, b) size of the load and c) how they plan to obtain the test weights. If they can’t answer all three, then and there (without going back to the office or making a call) strike them off the bidders list.

 

Explicitly Include Load Testing in Your Bid Specs


Lastly, explicitly include the requirement of an ANSI/OSHA load test in your bid specs. It’s always easier to explicitly include it in the specs rather than argue about it later. 

 

The Two Legitimate Crane Overloading Situations

Legitimate Overload Situations


Earlier I wrote about “Rated Capacity” and “Capacity” in determining what an overhead crane can legitimately lift. There are in fact two occasions in which it is legitimate to overload a crane. The first case is the initial load testing of the crane after installation which is a mandated overload test prior to releasing the crane for operation. The crane is to be tested at the ASME prescribed 125% of the Rated Capacity. This overload is usually performed by the crane builder and/or installer. The other legitimate crane overload is called a “Planned Engineered Lift,” which may never happen in the life of the crane.

A Planned Engineered Lift

A “Planned Engineered Lift” is a lift in excess of the “Rated Capacity” of the crane. Its name is especially appropriate in that the above Rated Capacity lift is to be a “planned” event and under the auspice of “engineer(s).” In other words, this is not an “ad hoc”, spur of the moment event. Further, the entire lift “system” is to be analyzed. 

Finding the Weakest Link

This is a good point to remember the old saying about “you’re only as strong as the weakest link.” In a “Planned Engineered Lift” the chain includes;
1. The rigging attached to the load
2. the lower block assembly
3. the wire rope
4. the hoist mechanicals
5. the hoist trolley
6. the bridge beam
7. the end trucks
8. the bridge beam to end truck connection
9. the runway rail
10. the runway support beam
11. the runway columns
12. the column footings

Overloading a Crane by the Book

Specification ASME B30.16-2007, Section 16-3.2 explains how these special overload lifts are to be conducted. Cranes are allowed to lift weights in excess of their rated capacity in two circumstances.

A. Initial Installation Load Test- mandatory overload test
B. Planned Engineered Lifts- overload condition that may never be incurred

In this post, we’ll delve into the latter, Planned Engineered Lifts.

PLANNED & ENGINEERED

As the name would imply, this is not a “willy nilly” over capacity lift, but rather a planned event that requires detailed written instructions with appropriate engineering calculations. Here’s the criteria;

1. Only cranes/hoists over 5 tons in capacity are eligible for this process
2. Cannot exceed 125% of Rated Capacity, except as provided in line item 4
3. Shall be limited to two such events in any continuous 12 month period
4. The hoist manufacturer must be consulted if load is to exceed 125%

Each Planned Engineered Lift event must include the following;
1. a review of the history of the hoist, including past mods and maintenance
2. an engineering analysis of the crane including, mechanical, electrical, pneumatic, and hydraulic components
3. a review of the hoist supporting structure
4. a full hoist/crane inspection prior to the lift
5. the lift shall be undertaken under the supervision of a single designated person
6. the initial lift shall be made such that it just clears the ground and then is stopped to check that the hoist brake can handle the overload
7. upon the brake successfully holding the load, the Planned Engineered Lift can proceed
8. upon completion of the Planned Engineered Lift, a complete inspection of the crane shall be performed
9. the inspection records and a writeup of the Planned Engineered Lift shall be included in the equipment file

The Intent of the “Planned Engineered Lift”

This procedure provided for two things;
1. A safe process for special circumstance above capacity lifts
2. The total elimination of the old concept of making “ad hoc” over capacity lifts, because the safety factor has been built into the crane.

An Extra Precaution (CYA)

Although not required, I would suggest that a representative of the hoist company or crane builder be on-site for the lift. Most modern cranes are equipped with a complex electronic overload protection system. If this system is bypassed for the lift (which will have to be done), you could void your warranty. Further, you’ll want to make sure the overload protection system is back in operation after the Planned Engineered Lift is completed. Most importantly, by having a factory rep on site and performing the overload bypass, none of your maintenance crew need become acquainted with the process of defeating the over load system.

The above article is an overview of the topic, and not intended as a replacement of the ASME specs. For a detailed writeup of Planned Engineered Lifts, see ASME B30.16-2007 Overhead hoists, page 20, Section 16-3.2 Handling the Load. 

Averages Can Be Dangerous

Averages, Rates and Rules of Thumb

Tons per hour, dollars per pound, gallons per square foot, times and rates per unit are a indispensable tool for engineers and estimators. As important and insightful as they are,  little mental shortcuts, blindly followed, can lead to big problems.

As a young crane salesmen, I received a request for quote spec, on an overhead crane for a steel coil loading application. (It’s been over thirty years, so I’m reconstructing these numbers for illustrative purposes.) I read through the specs and determined the plant operated two shifts, six days per week and at through-put of 160 coils per week.

Running the Numbers

I ran the numbers and with two shifts times six days we had twelve shift per week. 160 coils/week divided by twelve shifts is only 13.3 coils per shifts or just 1.6 coils per hour. This application appeared to be a real “snoozer”, a standard duty CMAA Class “C” crane would more than handle this almost restive application.

After writing up the estimate and submitting my proposal, I waited a couple of days to do a follow-up call. Much to my surprise, the customer said my price was ridiculously low and he threw out my proposal.

100% Correct Facts, 0% Correct Conclusion

 I asked if I could come to his office and take a few minutes of his time to review my proposal. He agreed. Looking back, I was lucky this old crusty engineer was willing to spend some time with this obviously very green crane salesmen.

After just a few questions from me, it became all too obvious the mistake I had made. 

In spite of the fact that the plant operated two shifts, six days a week, the company only loaded the coils on the second shift on Saturdays. What looked to me like lethargic 1.6 coils per hour was really a “gut busting” 20 coils per hour on Saturday evening. Continuous duty at full capacity for eight straight hours!

Had this buyer been, the all too common buyer that looked at price only, I would have wound up with a disaster on my hands. It’s very likely that my crane would have failed on the very first Saturday evening. At best, the motor heaters would have kicked out in the first hour or two before any real damaged occurred. In this best case scenario, I would have had a customer unwilling to pay my bill and probably a pile of subsequent legal bills.

Worst Case is More Important the Average Case

Averages rates/unit and rules of thumb are important tools, more than important, they are essential tools. Averages are helpful, but always make sure you're aware of the worst case too! The really good estimators have insightful “rules of thumb,” but equally important, they know when these numbers hide information rather than reveal insights.

Heavy does NOT equal Heavy Duty

Crane Terminology is Critical

Sometimes feel like I’m channeling Miss Sanders, my 80 year old, grade school grammarian Commandant, because all too frequently, I come back to writing about words and their usage. Unfortunately, words are all we have and how we use them is critical, especially in engineering and business contracts.

My "Word Rant of the Day" involves “Heavy” and “Heavy Duty.” These words are all too often used interchangeably and that lays the foundation for confusion.

Heavy Crane

Heavy is a relative term. I’ve had customers call and talk for 20 minutes about their need for a “heavy” crane, only to find out we're talking about a half ton, hand push crane with a chain fall. Whereas my steel mill clients referred to their 20 ton cranes as "the little cranes.”

Heavy Duty Crane

Heavy Duty in not a term of weight or size, but rather a term of usage. Heavy Duty is a commentary on the number of picks per hour, the average “on-time” minutes of the motors and the percentage capacity of the loads. It’s the amount of work being performed by the crane. This is better described as Duty Cycle. 

A more accurate indication of Duty Cycle is the CMAA use of Class A, B, C, D, E and F or the HMI hoist classifications of H1, H2, H3, H4 and H5.

The Right Words at the Right Time

There’s nothing wrong with using either “Heavy” or “Heavy Duty,” but just make sure to use “Heavy” in relation to weight and “Heavy Duty” in relation to Duty Cycle.

(For some reason, I get the feeling that Miss Sanders is looking over my shoulder and snickering?!?)

Is a Bridge Crane and an Overhead Crane the same thing???

Basic Crane Terminology

Bridge Crane = Overhead Crane = Overhead Bridge Crane = Electric Overhead Traveling Crane (EOT Crane)

They're all the exact same thing. 

The main structure which spans the width of the bay is the Overhead Bridge Crane. Also know as the Overhead Crane or Bridge Crane. All these terms mean exactly the same thing. In it simplest form the bridge consists of two end trucks, a hoist and a bridge beam (bridging between the two end trucks). 

A simple overhead bridge crane

End Trucks

The end trucks are located on both ends of the bridge girder. The end trucks provide the longitudinal motion of the crane as compared to the lateral traversing motion of the trolley. The crane hook coverage as measured from the longitudinal wall to the hook is called “hook end approach.” The end truck wheels ride on the runways allowing coverage of the length of the building. 

Bridge Girder

The horizontal beam of the bridge girder supports the hoist. There can be either one or two bridge beams ( single and double girder configuration). The bridge girder is either a structural shape, like an I-beam or a wide-flange, or a fabricated box.

Trolley

The trolley carries the hoist across the width of the crane. It travels along the bridge girder providing lateral motion. The longitudinal travel is the bridge motion where the lateral motion is trolley motion. The side wall to crane hook is called “hook side approach.”

Hoist

the hoist is mounted to the trolley and performs the lifting motion. The hoist is by far the most expensive component of the whole crane assembly.

Runway

The runways are the gray objects in the drawing. They are the rolling surface upon which the bridge cranes travel the length of the building. Several cranes can operate on a single runway, provided the runways were designed for the loadings incurred. According to a ten year study by the United States Steel Company, poor runways are the most common cause of crane problems.

These are the most basic parts of an overhead bridge crane. For a detailed Glossary of Crane Terminology, click the button below.

 

 

 

 

 

What Does "Capacity" Really Mean?

Crane Capacity Vs. Crane Rated Capacity

Since I wrote the last post, I've been concerned that I glossed over a very important point. One of the risks of writing about something you've been involved with all your life is that u take for granted the use of "insider" terminology. I pride myself in avoiding this writer's roadside landmine most of the time, but I think it got me on my last post.

Crane Capacity

This seems like an obvious and easily defined term, but frequently the obvious answer is not necessarily the correct answer. In the early part of the 20th Century, engineers had to deal with two factors that we now take for granted. Steel producers couldn't manufacture steel with the production uniformity commonly assumed today. Further, computers with tools like finite element analysis were not even thought of. As a result, engineers added in "safety factors." 

Safety Factors on Top of Safety Factors

In the original crane industry specifications, a 5:1 safety factor was mandated. This safety factor was on top of the safety factor the steel producers and that used by prudent engineers. It's little wonder that experienced crane operators determined that their cranes could in fact lift far more that the posted limit. 

Enter CAD (Computer Aided Design)

We now have precision production and engineering. The steel producers measure all the inputs and outputs, producing steel that precisely meets their spec... no more, no less. Engineers can now cut out excess steel (and therefore costs) using CAD to produce exactly what's required, again, no more and no less. In other words, all of the redundant safety factor has been removed.

The Weakest Link

It is important to remember that rarely are the cranes independent of a building as a supporting structure. If I remember correctly, metal building specs only require a 2:1 safety factor in the design of their structures. To me this provides a frightening mental picture of a severely (5x) overloaded crane, not equipped with overload protection, in a metal building engineered with a 2:1 safety factor!!!

Crane Rated Capacity

 So this is why, in the late 1980's, the crane industry started using the term "Rated Capacity." The Rated Capacity of all cranes, new and old, should be determined and marked appropriately. All new cranes should be equipped with overload protection and all old cranes should be retrofitted with overload protection. 

Without overload protection, you may wake up one day to collapsed building, laying on the ground in pieces, with a fully intact crane ready to make another dangerous lift.