PART 3: Don't Leave Home Without Them

Trying to separate the wheat from the chaff in OSHA

IGNORANCE IS BLISS… UNTIL IT’S NOT

In PART 1, we started from the position of “ignorance is bliss,” believing that OSHA 1910.179 Regulations for Overhead and Gantry Cranes was our whole crane safety universe. The only requirement for a crane inspection was to hand it off to a professional crane inspection company, to outsource the headache.

In PART 2 we discovered the ugly fact that OSHA 1910.179 Overhead and Gantry Cranes was not the “be all/end all,” and through 1910.6 Incorporation by Reference, about another three-dozen specifications slipped in the back door and landed squarely on our desk.

Now, what do we do with this pile of crane regs???

 
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COPING WITH INFORMATION OVERLOAD

In PART 3, it’s time for a real-world assessment of where we stand. It’s critical to remember we are talking about rules implemented by highly skilled technicians but not Supreme Court clerks sifting through piles of documents for legal precedent. In other words, how can we reduce the information overload created in PART 2?

I will divide this avalanche of information into three buckets;

  1. Primary EOT Crane Inspection Docs- These are docs to have on hand at all times.

  2. Secondary EOT Crane Inspection Docs- These are docs that it would be advisable to reproduce the relevant sections and keep in a ring binder. This binder should be in the inspectors truck or in the maintenance office if the inspections are being done “in-house.”

  3. EOT Crane Inspection Reference Library- These are documents that should be kept in a universally accessible library.

In the first two papers, I dealt in facts only, not opinion. In this paper, I will be falling back on opinion gathered over four decades of experience, tempered by the views of numerous friends in the industry with equivalent time in the trenches. I don’t mean to say that any of the three dozen references are unimportant, but rather those you should always have at your fingertips vs those in your reference library. To paraphrase the American Express commercial, “Don’t leave home without it them.”

PRIMARY EOT CRANE INSPECTION DOCUMENTS

  1. Manufacturer’s O&M Manual
    IMPORTANT NOTE: The Manufacturer’s O&M manual is most often forgotten or lost, but OSHA defers to it as the absolute bible for that specific piece of equipment. The quality of these manuals, especially the more modern ones, often leave a lot to be desired, but what they do contain is critical information.

  2. OSHA 1910.179- (Occupational Safety and Health Act) Regulations for Overhead and Gantry Cranes

  3. ANSI B30.2- (American National Standards Institute) Overhead and Gantry Cranes

  4. CMAA Spec 78- (Crane Manufacturers’ Association of America) Standards and Guidelines for Professional Services Performed On Overhead and Traveling Cranes and Associated Hoisting Equipment
    This is the least known but most important of the CMAA specs when talking about inspections. Should you ever find yourself in regulatory or legal jeopardy, you can’t go wrong quoting chapter and verse from the Association of Crane Manufacturers own document.

  5. CMAA Overhead Crane Inspection and Maintenance Checklist

  6. ANSI B30.10- Hooks
    This too, is one of the “sleeper” docs, but hook inspection is one of the few prescriptive requirements of OSHA. Written hook inspections by qualified persons are required monthly and frequently never done.

  7. ANSI B30.30- Wire Rope
    Same as the above note on B30.10, Hooks.

SECONDARY EOT CRANE INSPECTION DOCUMENTS

  1. OSHA, CMAA and ANSI B30 Letters of Clarification
    The Letters of Clarification for OSHA, CMAA and B30 are an absolute treasure trove of information, virtually unknown by the average crane owner or inspector. I put these Letters of Clarification at the top of the second group because they often address confusing issues from the spec docs.

  2. CMAA Spec 70- Overhead and Traveling Cranes
    It should be noted that OSHA 1910.179 Regulations for Overhead and Gantry Cranes specifically applies only to CMAA Spec 70 type cranes. Yes, that’s what it says and what OSHA has confirmed in multiple Letters of Clarification.

    As to why CMAA 70 is in the second tier of documents; it only contains 39 words regarding overhead cranes inspections and specifically references Spec 78 for inspection related issues.

  3. CMAA Spec 74- Top Running & Under Running Single Girder Cranes
    Although OSHA 1910.179 Regulations for Overhead and Gantry Cranes only requires inspections of CMAA 70 type cranes, all non-CMAA 70 cranes then fall under the requirements of the General Duties Clause… “Gotcha.” FYI, the General Duty Clause should therefore be your motivation for inspection of ALL lifting devices including CMAA 74 cranes, Enclosed Track Cranes, Jib Cranes and Monorails.

  4. CMAA Spec 79- Crane Operators Manual
    Much like CMAA 78, when in doubt, you can’t go wrong following the guidelines of the association made up of the crane builders. In this case specifically the “Pre-Shift” inspection paragraphs.

  5. ANSI B30.11- Monorails and Underhung Cranes- (to be folded into B30.17)
    See CMAA 74 explanation.

  6. ANSI B30.16- Overhead Hoists (Underhung)
    See CMAA 74 explanation.

  7. ANSI B30.17- Cranes and Monorails (With Underhung Trolley or Bridge)
    See CMAA 74 explanation.

  8. NFPA/NEC 70- (National Fire Prevention Association/National Electric Code) Article 610 Cranes and Hoists

  9. AISC Design Guide 7- (American Institute of Steel Construction) Minimum Design Loads for Buildings and Other Structures
    Specifically regarding crane runway alignment tolerances. Note, Design Guide 7 goes beyond the simple Table 1.4.2-1 - CRANE RUNWAY RAIL TOLERANCES from CMAA 70 and is therefore an essential spec in your reference library.

EOT CRANE INSPECTION REFERENCE LIBRARY

  1. ANSI B30.9- Slings

  2. ANSI B30.20- Below the Hook Lifting Devices

  3. ANSI A90.1- Safety Standard for Manlifts, IBR approved for 1910.68(b)(3) (for crane inspection and service)

  4. ANSI A92.2- Standard for Vehicle Mounted Elevating and Rotating Work Platforms (for crane inspection and service)

  5. ANSI A120.1- Safety Code for Powered Platforms for Exterior Building Maintenance (for crane inspection and service)

  6. ANSI Z244.1- Safety Requirements for the Lock Out/Tag Out of Energy Sources

  7. ANSI A14.3- Safety Requirements for Fixed Ladders

  8. ANSI A1264.1- Safety Requirements for Workplace Floor and Wall Openings, Stairs, and Railing Systems

  9. ANSI Z241- Safety Requirements for Melting and Pouring of Metals in the Metalcasting Industry

  10. ANSI Z535.4- Product Safety Signs and Labels

  11. ANSI/SAE Z26.1- Safety Glazing Materials for Glazing Motor Vehicles and Motor Vehicles Operating on Land Highways (for Crane Cab windows)

  12. AWS D1.1- (American Welding Society) Structural Welding Code Steel

  13. AWS D14.1- Specification for Welding of Industrial and Mill Cranes and Other Material Handling Equipment

  14. ECMA 15- (Electrical Control Manufacturers’ Association) Specifications for Cable-less Controls for Electric Overhead Traveling Cranes

  15. ECMA 25- Specification for AC Inverters for use on Electric Overhead, Monorail, and Gantry Traveling Cranes

  16. MHI/HST 4- (Material Handling Institute) Performance Standard for Electric Wire Rope Hoists

  17. MHI/HST 1- Performance Standard for Electric Chain Hoists

  18. NFPA 70- National Electric Code

  19. NFPA 70E- Standard for Electric Safety in the Workplace

  20. MBBA (Metal Building Manufacturer’s Association) Metal Building Systems Manual-
    Specifically regarding crane runway alignment tolerances.

  21. AIST (American Institute of Steel Technology) Technical Report TR6- Specification for Electric Overhead Traveling Cranes for Steel Mill Service
    Specifically addresses mill duty overhead cranes. These are cranes that exceed CMAA 70 requirements to meet the rigor of steel mill applications.

  22. AIST (American Institute of Steel Technology) Technical Report TR13- Guide for the Design and Construction of Mill Buildings
    Specifically regarding crane runway alignment tolerances.

  23. AISC (American Institute of Steel Construction) Manual of Steel Construction-
    Specifically addresses steel manufacturing tolerances (straightness) as well as fabrication and installation tolerances.

As you can see, this can be an overwhelming list of documents. Worse yet, the cost of acquisition is dwarfed by the cost of time to grasp material. The primary group of reference docs are required of any crane owner/inspector. The secondary group is highly recommended. As to the third reference group, I would advise you to acquire them over the years, as specific issues arise.

Here’s where you can buy the above listed documents;

AISC- American Institute of Steel Construction- www.aisc.org

AIST- American Institute of Steel Technology- www.aist.org

ANSI- American National Standards Institute- www.ansi.org

ASME- American Society of Mechanical Engineers- www.ASME.org

AWS- American Welding Society- www.aws.org

CMAA- Crane Manufacturer’s Association of America- www.mhi.org/cmaa

ECMA- Electrical Controls Manufacturers’ Association- www.mhi.org/ecma

MBMA- Metal Building Manufacturers’ Association-www.mbma.com

MHI- Material Handling Institute- www.mhi.org

NFPA- National Fire Protection Association- www.nfpa.org

OSHA- Occupational Safety and Health Act- www.osha.gov

Next in PART 4, we’ll start grinding out the details of our EOT Crane Safety Plan so that we can submit a detailed written RFQ to our inspection bidders.

Larry Dunville