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 .