OSHA Crane Operator Regulations and Recordkeeping

Transcription

1 OSHA Crane Operator Regulations and Recordkeeping Matthew Eckstine, Manager of Business Development National Commission for the Certification of Crane Operators Ray Feidt, Inspection/ Training Manager Stephenson Equipment, Inc. Presentation Overview History of crane operator certification and NCCCO Scope of Federal Rule: OSHA 1926 Subpart CC Crane Operator Certification/ Qualification Inspection and Maintenance/ Repair Employee Qualification Recordkeeping and documentation requirements Training of maintenance, repair and inspection personnel requirements NCCCO Program History 1987: Industry responds to: Unacceptable number of crane accidents Many apparently attributable to operator 1989: Tower Crane Accident in San Francisco Real cost much higher than realized Personal Injury/ Property Damage Worker s Comp/Lost Time Safety Record/ Mod. Rate Training only effective if learning is verified Verification through operator certification 1

2 National Commission for the Certification of Crane Operators NCCCO formed January 1995 Independent, non profit 501(c)6 organization Task: develop effective performance standards for operators, signalpersons, riggers, inspectors and all other crane personnel Provide a fair, independent and reliable assessment of knowledge and skill Does NOT provide training CCO Certified: 100,000 & Counting 5 NCCCO Certifications by the Numbers 25 certifications in 10 categories 100,000 individuals certified (since inception) 79,000 currently certified More than 240,000 certifications issued 850,000+ tests administered 140+ training firms nationwide (unaffiliated) Updated July

3 Available Certifications Mobile Crane Operator Telescopic Boom Fixed Cab (TSS) Service Truck Crane Operator (STC) Telescopic Boom Swing Cab (TLL) Lattice Boom Truck (LBT) Lattice Boom Crawler (LBC) Tower Crane Operator Overhead Crane Operator Articulating Crane Operator Digger Derrick Operator Available Certifications Signalperson Rigger Level I Level II Crane Inspector Mobile Crane Tower Crane Overhead Crane Lift Director Mobile Crane Tower Crane OSHA 1926 Subpart CC Cranes and Derricks in Construction 3

4 OSHA Rule Timeline : Advanced Notice of Proposed Rulemaking : Subpart N Work Group Meets 2002: OSHA announces intent to use Negotiated Rulemaking 2003, July: First CDAC Meeting 2004, July: Final CDAC Meeting 2004, October: ACCSH Supports C DAC Consensus Document 2006, October: SBARP Report Submitted 2008, Office of Management & Budget Review Finalized 2008, October: Proposed Rule Published 2009, March: Public Hearings held at Department of Labor 2009, June: Final Submission of Written Comments 2010, August 9: Final Rule Published 2010, November 8: Effective Date 2014, November 10: Four Year Phase In Expired 2017, November 10: Three Year Delay Ends Federal Proposed Rule (CDAC) Scope Definitions Ground Conditions Assembly/Disassembly Power Line Safety Inspections Wire Rope Safety Devices/Operational Aids Operation Signals Fall Protection Work Area Control Keeping Clear of the Load Free Fall and Controlled Load Lowering Qualifications and Training of Operators, Signal Persons, Maintenance & Repair Employees Hoisting Personnel Multiple Crane Lifts Design, Construction and Testing Equipment Modifications Tower Cranes, Derricks, Floating Cranes, Overhead Cranes, Pile Drivers, Sideboom Cranes, Equipment </=2,000lbs capacity, Severability Scope of Federal Rule Covers all power operated equipment, when used in construction, that can hoist, lower and horizontally move a suspended load. Mobile, tower and overhead cranes, including gantry cranes; articulating/ knuckle boom when used in certain applications; pipelayers or side boom cranes. If used in construction and is specifically designed to hoist and move a suspended load 4

5 Scope of Federal Rule Cranes and Derricks in Construction OSHA Letters of Interpretation Construction vs. Maintenance Operator Certification/Qualification More than 2000 lbs. of maximum rated lifting capacity Excluded: Derricks, Sideboom cranes, Other Partial Cranes Covered OSHA : Scope Various Exclusions 13 Exclusion Examples Aerial Work Platforms Forklifts Except when equipped with winch or hook Overhead Cranes Permanently installed Digger Derricks Work related to poles carrying electric and telecommunication lines (Subpart V) Service/Mechanic Trucks When used in activities related to equipment maintenance and repair Articulating Cranes Complicated material delivery exclusion

6 Crane Operator Training Transitional Period (c)(2) During the four year phase in, employers must train and evaluate employees who have not yet been certified/qualified Exempted Crane Operators (c)(3) ALL crane operators must be trained on the safe operation on the equipment the operator will be using 16 Training Requirements Who must be trained? (d) The employer must train each competent and qualified person applicable to their role Who are Competent and Qualified persons? Operators, Signal persons, Riggers, Maintenance and Repair employees, Inspectors, A/D directors How is this verified? (g)(1) The employer must EVALUATE each employee required to be trained under this subpart to confirm that the employee understands the information provided in the training. 17 Operator in Training Employer must provide sufficient training Tasks limited to the operator s ability Exclude certain activities (e.g. close to powerlines, hoisting personnel) Must be continuously monitored by an operator s trainer 18 6

7 Crane Operator Qualification/ Certification Requirements OSHA 1926 Subpart CC Who needs it? Any employee operating a crane with a maximum rated capacity of more than 2,000 lbs, working in a construction (or constructionrelated) application, such as Propane Tanks Precast components/structural members (e.g. sewer pipes and electric vaults) Outdoor Signs Municipalities/Public Works 20 Who MIGHT need it? Municipalities/Public Works Site specific requirements Mining sites GC/CM site requirements Army Corps of Engineers sites State/local jurisdictions The future is certification 21 7

8 US Licensing Requirements 2015 WA ME OR** NV CA ID UT MT WY CO ND SD NE KS MN WI IA IL MO MI OH IN KY TN WV VT NH NY MA CT NJ RI PA MD DE VA NC AZ NM OK AR MS AL GA SC TX LA AK FL : Recognize or require CCO Certification by law HI : CCO Certification not recognized in legislation : Licensing not required **Mandatory Training Requirement Only 22 Maintenance & Repair Employee Qualifications Operation of equipment limited to functions necessary to perform their work Requires one of the following: Direct supervision by certified/qualified operator Individual is familiar with operation, limitation, characteristics and hazards associated with the type of equipment Must be a qualified person Effective Date: November 8, Certification/Training Costs Who pays for the certification? (a)(4) Whenever operator qualification or certification is required, the employer must provide the qualification or certification at no cost to operators who are employed by the employer. Who pays for the training? (g)(3) Whenever training is required, the employer must provide the training at no cost to the employee. 24 8

9 Are You Ready? Federal OSHA Extension of Operator Certification Deadline Impact: Employers must still ensure that operators are trained and competent [29 CFR (k)(2)]. States and cities with licensing requirements are unaffected by the delay. Operators and employers must continue to comply with local licensing requirements. Requirements for operator certification are postponed, not rescinded. Federal OSHA Why delay operator certification? OSHA states that this is necessary so that the agency can engage in rulemaking to fix two provisions: Type and Capacity Would increase testing costs and burdens on employers No evidence that testing by capacity increases safety Certification = Qualification Would have eliminated employer s responsibility to ensure operator was qualified to perform the specific work they are assigned to 9

10 What does that mean to me? Employers Must still train and determine competence of crane operators Operators Get Certified If certified Keep calm and carry on If my state has its own requirements 28 Crane Inspection, Maintenance & Recordkeeping Requirements OSHA 1926 Subpart CC Who Can Inspect? Competent Person Competent person OSHA Definition: one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Competent Person: A person that is capable of identifying hazards related to the type of work that is being done...and has the authority to take prompt corrective measures. In order for an employer to consider an employee competent as related to crane inspection, the person: must have enough knowledge of the crane that he/she is inspecting so that this person can identify hazards and must also be given authority by the employer to take prompt corrective action if immediate hazards are found during an inspection. 10

11 Who Can Inspect? Qualified Person Qualified person OSHA Definition: a person who, by possession of a recognized degree, certificate, or professional standing; or who by extensive knowledge, training and experience, successfully demonstrated the ability to solve/resolve problems relating to the subject matter, the work, or the project. Has a degree or certificate or has professional standing Or someone who has. In order for an employer to consider an employee qualified as related to crane inspection, the person: must have a degree or certificate, or professional standing; or have extensive knowledge, training and experience in the type of crane that they are inspecting and they have demonstrated they can solve problems related to the type of crane they are inspecting. extensive knowledge, training and experience OSHA Crane Inspections & (tower cranes only) Inspection Type Who Inspects Regulation Modified Cranes Inspection Qualified Person (a) Repaired Cranes Inspection Qualified Person (b) Pre assembly Inspection (tower Qualified Person (f)(2) cranes only) Post assembly Inspection Qualified Person (c) & (f)(3) Shift Inspection Competent Person (d) Monthly Inspection Competent Person (e) & (f)(4) Annual Comprehensive Inspection Qualified Person (f) & (f)(5) Severe Service Qualified Person (g) Cranes Idle for at least 3 months Qualified Person (h) What is a Modification to a Crane? Cranes have had modifications or additions if any of the following are effected: safe operation of the equipment such as modifications or additions involving a safety device or operational aid (i.e. the OEM LMI is removed and replaced with just a Load Indicator), critical part of a control system, power plant (i.e. the crane is repowered with a replacement engine that is lighter in weight than the OEM), braking system, load sustaining structural components, load hook, in use operating mechanism capacity (i.e. a pile driving hydraulic power unit is hung on the counterweight of a lattice boom crane.) 11

12 OSHA Who must approve Crane Modifications or Additions Option 1 The manufacturer approves the modification/addition in writing and provides replacement load charts, operation manuals, etc. and maintains the original safety factor. Option 2 If the manufacturer refuses to review the written request for approval of a modification/addition or fails to acknowledge the request within 30 days, or the manufacturer is no longer in business: a registered professional engineer who is familiar with the type of crane can review the proposed modification request and possibly approve it The engineer would provide the replacement load charts, manuals, etc. Option 3 If the manufacturer does not complete the review of the request within 120 days a registered professional engineer can be asked to review the request. If the manufacturer prohibits the modification with a written description of why they are rejecting the request, the modification cannot be done. The modification must be inspected by a qualified person. The inspector must assure the modification was done in accordance with the manufacturer or RPE s approval criteria. The inspection must include a functional test. Documentation is not required What is a Repair to a Crane? If the purpose is to bring an electrical, hydraulic, pneumatic, mechanical or structural component that is: not working, damaged, leaking or otherwise not functioning properly back to its OEM design characteristics so that it functions as it did when it was new, this is a repair, not a modification. OSHA (b) Inspection of Cranes that have been Repaired A qualified person must inspect a crane that has been repaired or adjusted. The inspection must: Determine if the repair/adjustment meets the manufacturers criteria or a registered professional engineers criteria if the manufacturer is not available. Include a functional test of the repaired/adjusted component. Documentation is not required. 12

13 OSHA (f)(2) Inspection of Tower Cranes prior to erecting the crane Before each tower crane component is erected, it must be inspected by a qualified person for damage or excessive wear. The inspection must focus on components that are hard or impossible to inspect after the crane is assembled. A component that is damaged or worn cannot be used until it is repaired. The repaired component must be reinspected by the same inspector that did the initial inspection. Documentation is not required A qualified person must inspect all tower crane components prior to erecting the crane. OSHA (c) Inspection of Cranes after Assembly A qualified person must inspect a crane after it is assembled The inspection must: Verify the crane is assembled in accordance with the manufacturers criteria. This inspection does not require that the entire crane be inspected, just that the crane is assembled per the manufacturers criteria. Documentation is not required. OSHA (d) Shift Inspection A competent person must inspect a crane each shift it is being used. Taking apart equipment components and booming down is not required as part of this inspection unless the results of the visual inspection or trial operation indicate that further investigation necessitating taking apart equipment components or booming down is needed. Documentation is not required. A competent person performs the shift inspection 13

14 (d) What to Inspect During a Shift Inspection 1. Control mechanisms for proper operation and labeling. 2. Control and drive mechanisms for wear, contamination by lubricants, water or other foreign matter. 3. Air and hydraulic lines for deterioration, leakage 4. Hydraulic system for proper fluid level. 5. Hooks and latches for deformation, cracks or excessive wear. 6. Wire rope reeving for compliance with the manufacturer's specifications. 7. Wire rope condition. 8. Electrical components for malfunctioning 9. Tires (when in use) for proper inflation and condition. 10. Ground conditions for proper support, including ground settling under and around outriggers/stabilizers cribbing, ground water accumulation, or similar conditions. 11. Crane set up level 12. Operator cab windows for problems that hamper the operator's view. 13. Rails, rail stops, rail clamps and supporting surfaces when the equipment has rail traveling. 14. Safety devices and operational aids for proper operation. OSHA (e) Monthly Inspection The monthly inspection is done by a competent person. The items that are inspected during the monthly inspection are the same items that are inspected during the shift inspection. Monthly inspection must be documented. The last three monthly inspection must be retained and made available to anyone that is doing an inspection on the crane. A competent person performs the monthly inspection Inspection Results Shift/Monthly Inspections If a problem is found during the shift or monthly inspection, an immediate determination must be made as to whether the problem will cause an immediate safety hazard. If the deficiency is determined to constitute a safety hazard, the crane must be taken out of service until it has been corrected. Does the problem cause an immediate safety hazard???? If it does, the crane must be taken out of service until repairs are made. 14

15 OSHA (f) Annual/Comprehensive Inspection At least every 12 months the crane must be inspected by a qualified person. The annual inspection must be documented. The last annual inspection must be retained and made available to anyone that does an inspection on the crane. A qualified person performs the annual inspection Inspection Results Annual Inspections For any problem that is identified during the inspection, an immediate determination must be made as to whether the problem constitutes a safety hazard. If it is determined that a problem is a safety hazard, the crane must be taken out of service until it has been corrected. If it is determined that the problem isn t an immediate safety hazard but a condition that is beginning to show wear, then the employer must ensure that the deficiency is checked during the monthly inspections. OSHA Required Safety Devices These Safety Devices must work properly. If the do not, the crane must be taken out of service until repairs are made. Level indicator, either built in our portable. (if the built in level is not working, it must be remove or tagged out) Boom backstops on lattice boom cranes (except derricks) Jib stops (on cable suspended jibs when installed) Hoist brake pedal locks on cranes with foot brakes. Holding valves on outrigger jack cylinders Rail clamps and rail stops for cranes on rails (except portal cranes) Signal horn, either built in or portable. (if the built in horn is not working, it must be removed or tagged out) 15

16 Required Operator Aids Boom hoist hi limit kick out on lattice boom cranes mfg. after Dec. 16, Luffing jib hi limit kick out on cranes with a luffing jib installed. Anti two block device with automatic function kick outs telescopic cranes mfg. after Feb. 28, 1992 Lattice boom cranes mfg. after Nov. 8, 2011 Anti two block warning device Lattice boom crane mfg. after Feb. 28, 1992 and before Nov. 8, Boom angle or radius indicator readable from the operators station (all cranes) Jib angle indicator on luffing jibs Boom length indicator on telescopic boom cranes. Load weighing device on cranes with maximum rated capacity over 6000 lb. mfg. after Mar. 29, 2003 Cranes mfg. after Nov. 8, 2011 Outrigger extension sensors Drum rotation indicator if the hoist drum cannot be seem from the operators position. Cranes Not In Regular Use OSHA (h) Cranes that have been idle for 3 months or more must be inspected by a qualified person in accordance with the requirements of a monthly inspection. This inspection is a monthly inspection but it is done by a qualified person instead of a competent person and The inspection must be documented. Operators Manuals All operators manual that have: Operational info., Set up info. and Assembly info. Must be available, in the cab. 16

17 OSHA Crane Regulations and Recordkeeping Thank You Matthew Eckstine, Manager of Business Development National Commission for the Certification of Crane Operators Ray Feidt, Inspection/ Training Manager Stephenson Equipment, Inc. Federal Rule Resources derricks/index.html Compliance Assistance Guide for Small Business Fact Sheets OSHA PowerPoint Presentation Frequently Asked Questions Final Rule documents (especially the Preamble) crane rule NCCCO Guide to OSHA s Personnel Certification and Qualification Requirements Contact Us: Matthew Eckstine, meckstine@nccco.org or ext. 203 Joel Oliva, joliva@nccco.org or ext