| ILE: ADVISOR |


me that OSHA lifted the OSHA verbiage directly from the B30.2 paragraphs)


3. CMAA 70: 37 total words on crane inspections 4. NEC 70, ARTICLE 610… No crane inspection sections, no crane inspection words, Zip-pity Do Dah, Zilch, Nothing!


So OSHA has a mere 667 words regarding crane inspections, and although OSHA pulled a fast one and quietly added about another 19,700 pages of regulatory documentation, these additional documents provide only another 777 words for a grand total of 1,444 words specifically about overhead crane inspection. 1,444 words can hardly be considered a “go to”


source for all the questions about EOT inspections. Issues like, who’s qualified to inspect EOT cranes, how often, what documentation is required, what exactly is required to be inspected, etc. By the way, at the time of the first draft of this paper you are reading, it had 2,519 words. Tat’s 74% more words than OSHA and all of its subsidiary documents, about EOT crane inspection requirements added together!


STRIKE THREE: OSHA’s GENERAL DUTY CLAUSE


Here’s the real kicker; where the Bible needed 10 Commandments, OSHA needs just one, the General Duty Clause. Section 5(a)(1) of the Occupational Safety and


Health Act of 1970, employers are required to provide their employees with a place of employment that is “free from recognized hazards that are causing or are likely to cause death or serious harm.” What this means is that regardless of whether OSHA has written a specific requirement, the employer is still held to the standards of the General Duty Clause. In other words, even if the crane owner has conformed to every element of OSHA and it’s 197 “Incorporated by Reference” helper specs, they may still be held responsible for a worker accident. Further, since in most states, injured employees are precluded from suing their employer under Workman’s Comp, the crane inspector and the crane repair company become the primary target in the crosshairs of the Plaintiff’s lawyer. Te “General Duty Clause” is the real world


equivalent the 1978 movie “Animal House” in which John Belushi and the Delta’s were put on “Double Secret Probation” by Dean Wormer.


A PRACTICAL PROPOSAL TO OVERCOME OSHA’S CLARITY PROBLEM:


A few years ago, the CMAA (Crane Manufacturers Association of America) created a helpful guidebook,


CMAA Specification 78: Standards and Guidelines for Professional Services Performed on Overhead and Traveling Cranes and Associated Hoisting Equipment. In spite of what might be the longest book title ever, it’s loaded with useful information. Here’s a rundown of the topics covered in CMAA Spec 78; 1. Crane Technician qualification requirements 2. Crane Inspector qualification requirements 3. Certification criteria 4. Continuing Education training requirements 5. Inspection types a. Pre-shift b. Frequent c. Periodic


6. Inspection checklist 7. Inspection frequency 8. Inspection documentation requirements 9. Load Testing


Tis spec book may not be the “Everything You


Wanted to Know About Crane Inspections,” but it’s the most comprehensive guide I’ve found, providing a proactive perspective on inspection and crane maintenance. Tis is by no means a perfect solution, but adoption of CMAA Spec 78 by both EOT crane owners and inspectors is a far better solution than the current system in which nothing is required, but in the event of an accident, everything should have been anticipated. Spec 78 provides both the EOT crane owner and the EOT crane inspector a reasonable level of performance to adhere to. It also provides the guy on the floor with the best shot at a safe working environment. It is only fair and reasonable for the crane owner and crane inspector to have a specific written checklist as to what is required of them. Further, it is only fair and reasonable for the person on the shop floor to also have a checklist of the minimum requirements for a safe workplace and therefore the knowledge to lodge a complaint if they’re not being provided. In lieu of specific requirements for crane inspections, to be a successful bidder (low bidder), inspectors must inspect less, do less or high cheaper and therefore less skilled inspectors. As the system is currently configured, there is no minimum baseline that inspection bidders must bid to. Tis creates a “race to the bottom” which is terrible for inspectors, crane owners and most of all the workers using the cranes. Are the guidelines provided by Spec 78 required?


In other words, in the event of an accident, can an owner or inspector take refuge in the statement, “… your Honor, we strictly followed the specification of the Crane Manufacturers Association, Spec 78.)


INDUSTRIAL LIFTING EXCHANGE SUMMER 2018 15


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