| ILE: ADVISOR |


STRIKE 2: OSHA 1910.6: INCORPORATION BY REFERENCE Most crane owners think 1910.179 is the full extent of crane regulation in OSHA. In fact, 1910.179 is just the tip of the iceberg. To fully understand the requirements of OSHA, you need to start with 1910.6, a little-known section called “Incorporation by Reference.” OSHA 1910.6 lists 197 other specifications and


regulations and gives them the full force of law. Tese specs include documents like the NEC (National Electric Code), AWS (American Welding Society codes) and 195 others. To give you an idea of the magnitude of 1910.6, if each of these “incorporated by reference” docs are 100 pages in length (a ballpark guesstimate), that’s another 19,700 pages to learn, and if they cost $100 each (ballpark price), it’s going to cost you $19,700 to find out what they say! Tis represents an unreasonable burden in both time and money for the average EOT crane owner.


After combing through this list of the 197


referenced documents, documents that are, because of “incorporation by reference” considered to be part


Where Do I Get B30.2 1943/1967 & EOCI61


Do you have the 1943 Version of B30.2? Does anybody???


A little-known issue regarding the requirements of OSHA is the Incorporation By Reference as stated in 1910.6. To make things even harder, 1910.6 calls explicitly out the B30.2 Overhead and Gantry Cranes 1943 and 1967 version as well as the EOCI (Electric Overhead Crane Institute, a precursor to the CMAA) 1961 version. Good luck in finding anyone of those three documents! The good news is that a few years ago, in an OSHA


letter of clarification, the OSHA representative stated that modern versions of listed specifications could be used as long as they are equal or more stringent than the original specifications.


At this time, the current versions are as follows;


• ASME/ANSI B30.2: Overhead & Gantry Cranes, 2016 (in place of 1943 and 1967)


• CMAA 70: Overhead xxx, 2015 (in place of EOCI 61)


I think it’s safe to say that both contemporary documents meet the “equal to or greater” clause. ASME/ANSI B30 docs are available at: https://webstore.ansi.org/ B30.2 Overhead and Gantry Cranes, $69.00 Hoist and Crane package: $264.00 B30.2: Overhead & Gantry Cranes B30.10: Hooks


14 SUMMER 2018 INDUSTRIAL LIFTING EXCHANGE


B30.16: Overhead Hoists (Underhung) Cranes Package: $196.00 B30.2: Overhead & Gantry Cranes, 2016 B30.11: Monorail and Underhung Cranes


B30.17: Overhead and Gantry Cranes, Top Running/Single Girder Underhung Hoists Overhead Crane and Gantry Package: $136.00 B30.2: Overhead & Gantry Cranes, 2016 B30.16: Overhead Hoists (Underhung) CMAA docs are available at:


http://www.mhi.org/publications?q=&sort=&page=1&fq=c at-bookstore:Standards


CMAA 70: Specification for Top Running & Gantry Type Multiple Girder Electric Overhead Traveling Cranes $105.00


CMAA 74: Specification for Top Running & Under Running Single Girder Electric Traveling Cranes Utilizing Under Running Trolley Hoist $105.00


CMAA 78: Standards and Guidelines for Professional Services Performed on Overhead and Traveling Cranes and Associated Hoisting Equipment $30.00


CMAA 79: Crane Operators Manual $10.00


of OSHA, I have determined the following four specs to be of primary concern to people involved with EOT cranes.


1. OSHA 1910.179: Overhead and Gantry Cranes (the master document)


2. ASME/ANSI B30.2: Overhead and Gantry Cranes, Top Running Bridge, Single or Multiple Girder, Top Running Hoist (incorporated by reference)


3. CMAA 70: Specification for Top Running & Gantry Type Multiple Girder Electric Overhead Traveling Cranes (incorporated by reference)


4. NEC 70, Article 610: Cranes & Hoists (incorporated by reference)


Unfortunately, after combing these four documents, I failed to strike gold or anything even close to gold for specifics on the requirements for EOT crane inspections. Here are the sad results; 1. OSHA 1910.179: 667 words about crane inspections


2. ASME/ANSI B30.2: 1,407 total words about crane inspections (members of B30.2 have repeatedly told


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