Does your Overhead Crane Meet OSHA Regulations?

15 comments

by  on September 2, 2014

Jason, an Assistant Manager with one of our Channel Partners, asks:

“I received a call from a customer for whom I had conducted an inspection. The customer stated they received an OSHA reprimand for not having monthly inspections on their cranes. They have 2 top-running bridge underhung trolley-type cranes. OSHA referenced 1910.179 J2IV and 1910.179 B1 as the violations.

In the book I have, 1910.179 B1 states that ‘this section applies to overhead and gantry cranes, including semi gantry, cantilever gantry, wall cranes, storage bridge cranes, and the others having the same fundamental characteristics. These cranes are grouped together because they all have trolleys and similar travel characteristics.’

Are the references for the reprimand accurate?”

Tom answers:

Some confusion exists among crane and hoist owners, users and service providers regarding crane configurations and the application of Federal OSHA 1910.179 regulations. Some of this confusion may be caused by the first definition in 1910.179 – (a)(1):A “crane” is a machine for lifting and lowering a load and moving it horizontally…”  Because all overhead crane configurations fit this definition to one degree or another, we tend to lump them together and assume that all are subject to these regulations.  This is not the case. I wrote an article on the subject entitled “Does OSHA 1910.179 apply?” To read the full article, go here.

A second resource I want to share with you consists of two OSHA interpretations:

Interpretation #1: Click here
Interpretation #2: Click here

Each interpretation makes it quite clear that OSHA 1910.179 does not apply to the crane types you describe. For OSHA to prevail on a General Duty Clause, which they have not cited, they would have to prove or establish risk of serious injury or death. If the operators are doing proper daily pre-operational inspections, or even inspections once per month, they are covered. These “Frequent Inspections” do not have to be documented. (ASME B30.17 & B30.16.)

ASME B30.16 covers the underhung hoist and the “hoist chains” cited in 1910.179(j)(iv). In short, OSHA doesn’t apply.

Below are some additional resources related to this topic:

Disclaimer:
This blog post is Tom Reardon’s opinion of the interpretation of the relevant sections of OSHA. The reader should seek a legal opinion.

{ 15 comments… read them below or add one }

Tom Reardon Tom Reardon October 5, 2016 at 4:26 pm

Hello James,

I was able to track down the B30.2 1967 standard that you are referencing. Par 2.1.4.5 treats fire extinguishers as a recommendation (should).

OSHA Interpretation #1 referenced above to Mr. Thomas Hagerty dated March 4, 1991, par (c)(3)states that fire extinguishers are not specifically required in cabs. (http://owl.li/AOst304TB2y)

This interpretation would supersede any language of Incorporation By Reference (on this subject) since the standard was published 20 years prior to the interpretation.

Tom

James Stolte October 3, 2016 at 2:32 pm

Tim, You stated in one of your responses that:
“Here are the facts:
OSHA 1910.179 Does not require a fire extinguisher in the cab of a cab operated crane.
ASME B30.2 Does require a fire extinguisher IN the cab of cab operated cranes.

OSHA 1910.179 Does have the power of law.
ASME B30.2 Does not have the power of law.”

In CFR1910.6 the ASME B30.2-67 is incorporated into law in its entirety. This means it does have the power of law.

Thanks,
Jim

Jessie Harrison July 7, 2016 at 12:38 pm

Cranes are one of the biggest machines on a construction site. Which means that they’re also a big liability. I’m sure there’s a lot of precautions to take. You mentioned many regulations in your article that have to be taken care of. Who do the inspections?

Tom Reardon Tom Reardon April 5, 2016 at 2:04 pm

Hi Tim,

Thank you for reaching out to us with your question. As you stated, the Interpretation #2 referenced above
(OSHA Interpretation letter to Mr. Thomas W. Hagerty, dated 03/04/91) is directly from OSHA:

(c)(3) Are fire extinguishers required in cabs? Fire extinguisher are not specifically required in cabs, and carbon tetrachloride extinguishers are prohibited. If a fire extinguisher is provided, the employer shall ensure that operators are familiar with the operation and care of the extinguisher.

Here are the facts:
OSHA 1910.179 Does not require a fire extinguisher in the cab of a cab operated crane.
ASME B30.2 Does require a fire extinguisher IN the cab of cab operated cranes.

OSHA 1910.179 Does have the power of law.
ASME B30.2 Does not have the power of law.

Hope this helps,
Tom Reardon

Tim Coleman March 25, 2016 at 12:18 pm

Hello

The attached letter states no fire extinguisher is required by OSHA, but ASME B30.2-1.5.4 does require a fire extinguisher;

A portable fire extinguisher, with a basic minimum extinguisher rating of 10 BC, shall be installed in the cab.

It is my understanding that OSHA 1910.179 is law but also ANSI B30.2 is also law. The reason I bring this up is I hear both sides and I would like to know your interpretation of the rule.

Thank you,

Tim Coleman

Ethel August 28, 2015 at 2:59 pm

It seems that the best way to get equipment functioning properly is to consistently get them evaluated and repaired when necessary. Safety should always come first! I agree with Delores, you want to make sure anyone that is going to be around the crane, will be safe. Thanks for answering this question.

Tom Reardon Tom Reardon August 24, 2015 at 12:53 pm

Grant,
Thanks for your comment.
You will have to refer to the OSHA 29 CFR Part 1926 Cranes and Derricks in Construction; Final Rule
https://www.osha.gov/FedReg_osha_pdf/FED20100809.pdf
Tom

Grant Harper August 20, 2015 at 10:16 am

It sounds to me like these crane regulations can get very complicated and can sometimes be difficult to understand. I work for a construction company, but usually we just do smaller projects, so we don’t always need cranes. However, soon we are taking on a fairly big project, so we need to hire some large cranes. I want to be sure that we don’t get into any trouble with the different regulations like this business did. To be sure that I am following all the rules, I will be sure that we find a good business to work with that knows plenty about all the various regulations.

Tom Reardon Tom Reardon February 3, 2015 at 11:03 am

Hi Delores,
Thank you very much for your comments. Performing regularly scheduled Frequent and Periodic Inspections increases crane safety and contributes significantly to increased reliability of the equipment.
Tom

Delores Lyon February 2, 2015 at 3:49 pm

I agree that it is important to make sure the cranes you use follow the safety regulations. The last thing you want is a malfunctioning crane, especially when there are a lot of employees around it. Maybe I should order an inspection of our own gantry cranes. They were checked a few months ago, but you never know!

Walter Kowalski December 1, 2014 at 3:25 pm

My son’s friend recently started his own construction business. He is bidding on a project that will require the use of an overhead crane. I’ll have to share the OSHA requirements with him.

Walter Kowalski | http://amquipinc.com/

Tom Reardon Tom Reardon October 8, 2014 at 3:18 pm

Thanks, Daniel.
I appreciate your kind words. It is always great to see that these articles are helping educate our readers. It was a pleasure to have you in class! Keep up the great work and stay safe!

Tom

Daniel Arwood October 6, 2014 at 10:39 pm

This was really informative! I’ve been through a lot of crane inspection training courses (and even Tom’s Static Stepless class) – but this is the first that I’ve heard that TRSG cranes are not covered under OSHA 1910.179.

I read the article and LOIs – and can’t believe this is so misunderstood in the industry.

Great article! Thanks for posting!

Gisela Clark Gisela Clark September 25, 2014 at 3:33 pm

Hi Julia,

Thanks for your comment and for sharing our blog. We would love to hear your husband’s thoughts!

Gisela

Julia Carlson September 25, 2014 at 11:17 am

My husband used overhead cranes often in his line of work. I think he would find this question interesting. I’ll have to show it to him.

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