OSHA Crane Inspection Family Tree- 2022 Update
About a decade ago, I created an "OSHA Family Tree" mind map for Overhead Crane inspections. I intended this document to be a comprehensive listing of all the related information essential to the regulatory requirements for Overhead Crane inspections. In the intervening years, Google analytics tells me that this is my website's most visited page. In addition, since I wrote the "OSHA Family Tree" page, I've consulted on many legal cases requiring me to get "hip deep" in the minutia of OSHA crane regs.
Last summer, I was engaged by a Fortune 100 company to put together a corporate-wide crane inspection program. They were frustrated that every vendor they talked to gave them a different answer about what exactly was required of them. They decided to use my firm, Overhead Crane Consulting, for the project when I told them, "Don't believe what anyone tells you when it comes to OSHA; whatever they tell you, your response should be, show me where it says that." Bottom-line, if the vendor can't show you the reference chapter and verse, find another vendor.
It's my experience that 80% of the OSHA-related information on the shop floor is a combination of hearsay and common-sense assumptions. But unfortunately, common sense has no place in the OSHA landscape because common sense changes from person to person, and hearsay changes with every person that relays the message.
Armed with this "show me" attitude, I sat down and started by listing all the questions I could think of regarding crane inspections. I then set out to find the precise "chapter and verse" answer to each question. As the project progressed, I was able to distill the dozens of questions down to just eight essential questions. In answering some of these questions, I had to find new sources of information. I discovered that I, too, had been relying on common sense and knowledge handed down to me over the years. Answers that, on the surface, made sense but, in fact, lacked foundation.
On the one hand, I felt good about distilling Overhead Crane inspection issues down to eight pivotal questions. On the other hand, I was shocked that I could not find a single one of the answers in OSHA 1910.179 Overhead and Gantry Cranes. Further, I realized that with less than 740 words in the 1910.179(j) Crane Inspections section, it should not be surprising that it contained no answers.
So, here are the eight pivotal questions;
Whose Rules Rule? If not OSHA, then what?
First, we need to establish that the answers are not in OSHA and realize that not 1910.179 but rather 1910.6 was the roadmap to our answers.Specifically, which regs do crane owners have to follow?
Next, we need to determine, if not OSHA, then where do we look?Exactly what types of cranes does OSHA require to be inspected? (This will shock you)
Top running cranes, under running cranes, single girder, double girder, jib cranes, monorails???What Overhead Cranes inspections are mandated?
Initial, recurring, modified???Who is authorized to inspect an Overhead Crane?
Are outside crane inspection companies required, or can in-house employees inspect?Specifically, what components should be inspected?
Do we have to open gearboxes, check contactors for pitting, and/or to what level of disassembly is required?What are the required inspections intervals?
Spoiler alert, there is no such thing as an "Annual Inspections."What Documentation is required?
Which inspections have to be in writing?
After extensive digging, the following documents are where I found the answers, and therefore, here is the 2022 version of my OSHA Family Tree for Crane Inspections.
OSHA Overhead Crane Inspection Family Tree