By Eric Carleton, P.E.
Precast concrete operations require heavy lifting. It’s what we do. This might include stripping steel formwork, transporting a full bucket of fresh concrete to be poured, or moving a massive precast concrete product from one side of the plant to the other or out to the yard. Because these are heavy lifts, it is imperative plant management and supervisors have specific safety rules and policies in place to limit the risks involved with suspended loads.
The Occupational Safety and Health Administration has developed different regulations for a variety of product handling and moving operations that the precast industry should fully understand. With myriad OSHA crane standards, there can be some confusion on which provision may apply to plant operations. The primary OSHA standard regulation detailing overhead crane operation and safe suspended load operation falls under the general industry standard 1910 in Title 29 of the Code of Federal Regulations, “Occupational Safety and Health Standards,” Subpart N, “Materials Handling and Storage,” specifically section 29 CFR 1910.179, “Overhead and Gantry Cranes.”
As defined within the standard 1910.179(a)(1): “A crane is a machine for lifting and lowering a load and moving it horizontally, with the hoisting mechanism an integral part of the machine. Cranes whether fixed or mobile are driven manually or by power.”
In addition, the standard states that an “overhead crane means a crane with a movable bridge carrying a movable or fixed hoisting mechanism and traveling on an overhead fixed runway structure.”
There are additional standards regarding truck or track cranes with a rotating superstructure and a boom, but this article will focus on overhead cranes.
OSHA has another section related specifically to construction activities, namely section 1926 in Title 29 of the Code of Federal Regulations (29 CFR 1926). Section 1926.1401, “Definitions,” states: “Overhead and gantry cranes includes overhead/bridge cranes, semigantry, cantilever gantry, wall cranes, storage bridge cranes, launching gantry cranes, and similar equipment, irrespective of whether it travels on tracks, wheels, or other means.”
The general industry standard (29 CFR 1910) describes fixed overhead cranes while the construction standard (29 CFR 1926) describes mobile overhead cranes.
Although precast plant operations fall under the general industry standard, there are many provisions in 1926 Subpart CC that provide excellent guidance and more detail about overhead crane safety than 1910.179. Though provisions within section 1926 Subpart CC may not be enforced for an industry application, such as operator certification, other pertinent provisions could be applied under the all-encompassing OSHA General Duty clause in the actual Occupational Safety and Health Act of 1970. It states: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
The clause is important because it can be used to cite an employer even when there is no standard. However, there is a provision that the hazard must be recognized by the employer. OSHA states that recognition of a hazard can be established by the employer, by the industry or by common sense.
To ensure OSHA compliance, and more importantly to maximize employee safety, it is important for management to fully understand the overhead crane provisions in section 1926 Subpart CC and implement them in the company’s safety plan with appropriate language and training.
What if your operation only uses fork trucks for lifting and moving product?
Though it is true general fork truck operations fall under the OSHA standard 1910.178, “Powered Industrial Trucks,” if an operator uses a factory-made or plant-made boom with a hook, chain or sling attachment then the lifting action has been defined within OSHA as a crane activity and falls under the corresponding crane requirements. An interpretation of this is on an OSHA Frequently Asked Questions webpage.1
When is using a forklift required to comply with the cranes standard?
Equipment that is designed to function as both a crane and a forklift is considered multi-purpose equipment and covered by the cranes standard when configured to hoist, lower (by means of a winch or hook) and horizontally move a suspended load. However, OSHA intends to propose amendments to the crane standard that will clarify that forklifts are excluded from coverage by the standard unless they are equipped with a boom/jib and a hoist and used like a crane.
Therefore, it is important to include an explanation of OSHA section 1910 and 1926 provisions on overhead crane use and operation in your plant safety plan.
Crane operator training
Proper safety training is a paramount element. When working with suspended loads, training can be lifesaving and should include everyone in the plant. Routine training helps to alert staff about overhead dangers, such as typical travel zones of the suspended loads, and develops a situational awareness mentality of the safety risks around workers when they are doing their normal tasks. There is one important difference between the two OSHA standards for crane operator training. Both specify that only company-designated individuals are permitted to operate an overhead crane (or any crane). However, on a construction site, the designated person must be trained by the employer and then certified from an acceptable national program as described in OSHA 1926.1427(c). Although operator certification is not required within the industry standard, the employer is required to understand the complexities of code language, or how one word or sentence can direct to another provision. This allows the OSHA standard to reference and direct the reader to other private or public codes and standards which must be understood and enforced.
With regard to the precast companies’ designated crane operator(s), section 1910.179(b)(8) states, “only designated personnel shall be permitted to operate a crane covered by this section.” Designated personnel is defined to mean “selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties.” In 1999, an OSHA standards interpretation letter defined designated at 1910.179(a)(35) as: Selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties. The key word within the sentence is “qualified.”
Because the term “qualified” is not itself defined, OSHA would interpret qualified in light of operator-qualifications provisions of industry standards such as ANSI B30.2 (“Gantry Cranes Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist”). Although the 1910.178 training requirements do not apply, you may also find it useful to consult that standard when developing a training or evaluation program for travel lift operators.2
In determining the training, education and qualifications of the designated crane operator, the provisions in the construction specification (excluding a required certification) could be used. But precasters must also be aware of specific regulations required by the state or province where the work is being done. OSHA regulations represent a national minimum requirement. However, each state can reference 1910.179 and add more stringent requirements in their jurisdiction or enact their own unique crane safety requirements as long as the requirements are not less stringent than the current OSHA code.
For example, Michigan’s Department of Licensing and Regulatory Affairs issued its own unique crane standard, “General Industry Safety and Health Standard, Part 18 Overhead and Gantry Cranes.”3Other states with unique industry crane regulations include California, Kentucky, Minnesota, Oregon, Utah and Washington.
Another important plant position involved in overhead load safety is the rigger. This person is responsible for ensuring proper connection of the hoisting device to item being lifted. Like the crane operator, there is an expectation by regulators that this person should be designated, hence qualified, for that critical function of safe overhead lifting.
The rigger may be the person responsible for assisting the crane operator to direct the load, keeping a clear path or using taglines to help position the load. If this is the case, the rigger needs to be trained to use the standard crane movement hand signals described in ANSI B30.2 or other lifting guides. In many precast plants, the crane operator has a remote control and can operate the crane on the production floor without the need for a specific signal person. However, during a hoist and overhead movement, safety experts agree that all employees in the vicinity of the lift must be trained to know the stop or emergency stop signal and have the authority to use it when they perceive an unsafe condition. ANSI B30.2 section 2-3.1.7, “Conduct of Operators,” states: “The operator shall obey a stop signal at all times, no matter who gives it.”
In addition, the rigger can add another valuable set of eyes to identify worn or dangerous lifting equipment during the mandatory daily or written monthly inspections of the crane and its components. More rigger training information can be found on precast.org in, “A Beginner’s Guide to Lifting Devices.”4
Knowing the safety standards is critical
Safety is everyone’s business. If your precast operation requires suspending loads, the regulations are clear that full understanding of the current national, state and even municipal crane operation regulations are needed to develop a comprehensive plan to assure best practices for a safe environment. If it has been a while since you took the time to read and review those best practices, the time to review them is now.
Eric Carleton, P.E., is NPCA’s director of codes and standards. He is an ASTM Award of Merit recipient and currently serves as vice-chairman of ASTM C13, Concrete Pipe.
Suspended Load Resources:
• OSHA 1910.170 Subpart N, “Overhead and gantry cranes” https://www.osha.gov/laws-regs/regulations/standardnumber/1910
• OSHA 1926 Subpart CC, “Cranes & Derricks in Construction” https://www.osha.gov/laws-regs/regulations/standardnumber/1926
• OSHA 1910.184, “Slings” https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.184
• ANSI B30.2-16, “Overhead and Gantry Cranes (Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist)” https://webstore.ansi.org/Standards/ASME/ASMEB302016
• Canadian Standards Association B167-16, “Overhead cranes, gantry cranes, monorails, hoists, and jib cranes” https://store.csagroup.org/ccrz__ProductDetails?viewState=DetailView&cartID=&portalUser=&store=&cclcl=en_US&sku=B167-16
• NPCA Guide to Plant Safety/Cranes https://precast.org/safety/
• CMAA 78-2014, “Standards and Guidelines for Professional Services Performed On Overhead and Traveling Cranes and Associated Hoisting Equipment (Revised 2015)” https://www.techstreet.com/standards/cmaa-78-2014?product_id=1913230
• CMAA 79-2012, “Crane Operators Manual” https://www.techstreet.com/standards/cmaa-79-2012?product_id=1913231#jumps
• OSHA National Alliances /Crane, Hoist and Monorail (CHM) / Products and Resources https://www.osha.gov/dcsp/alliances/cmaa_hmi_mma/cmaa_hmi_mma.html#!5B