Posts Tagged ‘jay sturm’

Dual-Purpose Machine Q&A

On mMay 24th 2016, Cranes101 hosted a Round Table meeting to discuss the unique nature of these Dual-Purpose Machines. We were glad to have such a diverse group of attendees at the event, because they brought their own perspective and knowledge on the subject to share with the group. We started off the discussion by explaining the difference between Bucket Trucks and Cranes stability. Then the conversation opened and we enjoyed a great afternoon of Questions and Answer. Below, here are the highlights from our discussion:

Bucket Trucks: 

Understanding Stability

Per OSHA, refer to the ANSI A92.2 standards for the stability test requirements.

  • The stability test is required to be done by the upfitter, i.e.; the person(s) responsible for attaching the base to the chassis, one time.
  • Truck should be stable at 150% of load when at its worst condition, i.e.; stick straight out.
  • Truck should be able to turn 360°.
  • If truck passes above requirements, this would be the last time a stability check is needed, unless further repairs are done on the truck.

Questions from this section

Question: Does an outrigger repair qualify as “further repairs”?

Answer: Yes. If it is a typical repair, it would require re-certification.

Cranes:

Understanding Stability for Suspended Platforms

Per OSHA, refer to the ASME B30.5 standards for the stability test requirements.

  •  The stability test is required to be done every time you move the crane.
  • The procedure includes;
    • 5-minute suspension test with 25% of the weight attached
    • Weight must meet OSHA’s specifications
    • Test pick which cannot exceed 50% of the basket’s capacity
    • Needs to include your expected capacity in the basket
  • A pre-lift briefing is required at ever stability test. Those in attendance must include;
    • Lift Director
    • Person(s) going in basket

Questions from this section

Question: After the test pick is done, is there a requirement to document the pick?

Answer: It is not required. However, for liability purposes, whenever a pick or test is conducted there should be proper documentation.

Question: Why must my suspension test take 5-minutes?

Answer: This is an OSHA requirement.

 

***DOCUMENTATION beats CONVERSATION!***

If there’s a record of it, you won’t have to talk about whether it’s done or not.

meeting Jay speaker

General Discussion:

Question: How should I go about identifying a Dual-Purpose Machine?

Answer: To date, OSHA and ANSI do not make reference on how to define a dual-purpose machine, so there is no guideline to go by. This is a loaded question that can only be answered by opinion since there is no verbiage on this. The term “Dual-Purpose Machine” is a relatively new term. Manufacturers are still discussing how they are going to handle these machines. So, you can’t always depend on your manufacturer to determine if your machine is dual-purpose. To properly identify this machine, there might be a bit of investigating.

You should also note that

  • You can attach a basket to a crane without making it a dual-purpose machine in some instances
  • Not all manufactures identify a machine as a dual-purpose machine.

 

Question: If you cannot make the determination as to if the machine is dual-purpose or not, then what becomes the default standard?

Answer: Our opinion is to have the manufacturer make that determination.

 

Question: Are any manufacturers currently selling clearly identified Dual-Purpose Machines?

Answer: National Crane will be releasing this machine in 2016.

 

Question: How are range limits achieved?

Answer: With a bucket truck, they typically turn 360°. A crane’s range limits are dependent on mechanical limitations, and the operator needs to be aware of this to test those limits before getting into the basket.

 

Question: Does OSHA require a documented daily inspection?

Answer: No. However, you should check with your employer as they might require it. Also, in the state of Massachusetts, it is a requirement to document your daily inspections.

 

Question: Does OSHA require a documented monthly crane inspection?

Answer: Yes.

 

Question: What standards should I follow for my dual-purpose machine if it is configured as a crane?

Answer: You should follow the ASME B30.5 standards, unless you attach a bucket. Then, you would be required to follow the ASME B30.23 standards.

 

Question: Where is it recommended that I add my notes to document that I did a test pick on my suspended platform crane?

Answer: A suggestion would be right in the daily inspection log under the comment section.

 

Question: Does Massachusetts have the same definition for cranes as OSHA does?

Answer: No.

 

Question: In your opinion, what is the most common cause in accidents for both bucket trucks and cranes?

Answer: Lack of training.

 

Question: How do I know what standards I should be following? What makes that distinction?

Answer: You need to know what industry you are categorized in. The same machine can fall under different standards, depending on what they are being used for. You need to be educated on the different standards and how and when they apply.

Question: In the standards, there is no mention to “use this dual-purpose machine” when feasible. Shouldn’t there be?

Answer: Sometimes there are voids in the standards. This may have been done purposely in order to open discussion for revisions.

 

Question: The use of equipment to hoist employees is prohibited, except in the OSHA 1926 subpart CC. Why is that?

Answer: This is a perfect example of balancing liability. Without an incident, it may not be a safety issue. However, you may be setting yourself up for a liability issue.

 

Question: When a scenario comes up where you are bidding a job, whose responsibility is it to assign the proper equipment for the job?

Answer: There is usually mention in the contract that the contractor will follow the most stringent requirement that applies. This can also depend on the culture of the job.

 

Question: If ANSI and ASME are considered voluntary standards, then this means that they are not the law. Also, good practices and manufacturer’s recommendations are not the law. So, what exactly is the law?

Answer: You need to meet OSHA’s requirements every time. If OSHA refers to an ANSI or ASME standard, then it has now become a law. If OSHA says to refer to your manufacturer, then the referral you receive from them is now the law. The rules of good practices can always exceed OSHA’s requirements, however, they can never come short from what OSHA expects.

On a side note, for liability purposes, you should know that lawyers are not restricted to consensus standards. This means that it is important for the employer to have an understanding of the expectations from all areas.

 

Question: How does the operator protect themselves and know how to operate a Dual-Purpose machine safely?

Answer: The operator must read and understand the operator’s manual.

 

Question: Can a company be cited if there is proof that their operator did not read and understand the operator’s manual?

Answer: Yes.

 

Question: If the machine is built to the A92.2 standards, do you still have to do a load test?

Answer: Only if you can prove that it is built to the A92.2 standards by identifying it on the plate. If the machine has a winch on it, it is now a crane.

 

Question: What if the machines winch is not functioning, i.e.; tied off, and you are using the machine to change light bulbs. What standard do you use?

Answer: OSHA 1910 Standards; because you are not using the machine for construction.

 

Question: Should the supervisor know how to run a Dual-Purpose machine?
Answer: Yes. The supervisor and anyone running the machine should be trained on how to operate these machines. This will broaden the understanding of how to safely operate this machine.

 

Question: What prevents an operator from flipping the switch and using the machine in a different way?

Answer: That has to come from management and discipline, separate from training. In our opinion, altering the functionality of the machine in any way that is unsafe or incorrect would be means for dismissal. This message needs to be clearly understood. Furthermore, having documentation that the operator has signed and understood how the machine is to be operated is a good practice for liability.

 

Question: Is there ever a time where working near power lines or radio towers causes interference?

Answer: Yes. When working with radio towers that has happened.

 

Question: How does the employer ensure safe operation of a Dual-Purpose Machine; or any piece of equipment for that matter?

Answer: Qualify the operator and document it.

 

Question: What are some suggestions for the manufacturer to best provide a safe machine?

Answer: Involve the operator/end-user when they are designing the machine.

The “Interpretation” Situation

I was asked a good question recently and have been asked similar questions like this before.

“You wrote my crane up as deficient because I didn’t have Electrocution Warning decals on all four sides of the crane. I looked at the standards and they don’t state that there needs to be Electrocution Warning decals on all four sides of the crane”

He’s right, it doesn’t say that specifically.  This item is representative of a number of articles in the crane standards that need to be interpreted for the best possible inspection.

Using this example, imagine if there was an accident involving a ground worker and electrocution. Let’s say that the ground worker touched the crane on the very side that had no electrocution warning and got injured as a result of the crane crossing electrical wires.

From where I sit, nothing is far-fetched. When you think of it, every accident wasn’t expected. That makes the art of safety a test to prevent everything that is unexpected.

OSHA provides crane safety standards that are the MINIMUM safety standards. Likewise, in the event of an injury, OSHA is the least of your troubles. Let’s get back to our injured ground worker…

The ground worker is hurt. OSHA levies a citation and fine at the hearing. The citation doesn’t involve the missing decal at all. In fact, maybe the OSHA inspector interpreted this standard differently or maybe he missed it during his investigation. (I wouldn’t ever expect OSHA to miss anything) So now what?

d1005 cupco electrocution warning decal 2         d1003 cupco electrocution warning decal 3

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                                               Need decals? We keep these in stock!                                                       Visit our shop 57 Mendon St. Bellingham, MA

I’ll tell you from experience. The ground workers lawyer does his investigation. He notices that there is no conspicuous warning label regarding the possibility of electrocution and he questions the crane safety standards. His interpretation is very specific.

His client (the injured ground worker) should have been able to approach this crane from any angle and be aware of the imminent electrocution potential. The ensuing lawsuit makes OSHA’s fine seem….. Minimal.

This is only one of many interpretation issues that I address during an inspection. My goal is to keep my customers and their workers safe and to prevent any scenarios like this from happening. Many items on my inspections are perpetuated from incidents that I’ve been involved in and outcomes of litigations that I’ve been involved in.

Be Safe, Be Healthy, Be Happy

- Jay Sturm

Update on Operator Certification and Recent OSHA Meeting in D.C.

Most of you who read this will be familiar with the draft proposed recently by OSHA regarding crane operator qualification which would replace the original wording of the 1926 (subpart CC) section 1427. This is the section where the operator certification and qualification requirements are covered. Copy and paste the following link to read the entire proposed draft: https://www.osha.gov/doc/accsh/accshcrane.pdf

In a nutshell, the draft was a rewrite of what qualifies and/or certifies an equipment operator, which includes a variety of crane types. In particular, the draft as written would require an extensive annual evaluation of the operator and require that the operator attend a very strenuous training program. The ‘proposed draft’ changed the current wording which states that operators are to be “certified by type and capacity of equipment” to “operators are to be certified by type of equipment.

As you might expect, there was an adverse reaction to this proposed draft, especially by employers of crane and equipment operators, since an annual evaluation of each operator would be extremely time-consuming and costly. Personally, I was not surprised by this proposed draft. I knew change was coming when OSHA extended the operator certification date because of the opposition of certain groups over operators having to be certified by type and capacity. Also, it was pretty obvious that OSHA had given serious thought to the subject of cranes, particularly to personnel who operate them, that certification did not equal qualification and there should be a greater emphasis on operator training, assessment and evaluation.

OSHA scheduled an ACCSH (Advisory Committee on Construction Safety and Health) meeting on March 2, to discuss the proposed draft. ACCSH is a 15-member advisory body that provides advice and assistance in construction and policy matters to the assistant secretary. ACCSH meetings are open to the public and are announced in the Federal Register. As you would expect, the room was full. CIC was represented by Tony Brown, Jeff Dudley, Pete Walsh and myself. Tony and I signed up to be speakers. When it came our time to speak, Tony and I both recommended to the ACCSH committee that the language requiring operators to be certified by type and capacity should remain in the regulation.

We made this recommendation based on the following reasoning: Half of the four accredited certification organizations (NCCER and CIC) developed their certification programs by type and capacity because OSHA said that would be the requirement. It just would not be fair to these organizations to change the original requirement for certification which was by type and capacity and force them to change their programs. That would not only be unfair, it defies common sense!

[I understand] there are operators that have certifications which are based on type only. Requiring them to be certified by type and capacity would cause them to be disenfranchised. Therefore, we recommended to the ACCSH committee that not only should type and capacity be left in the regulation, but the regulation should also allow operators to be certified by type. The standard would ultimately read that operators of equipment be certified by type and capacity or by type. We felt like this would satisfy all of the certification organizations and would be fair to all of them as well.

The next day, the ACCSH committee recommended by motion several things to OSHA. First, that OSHA needs to rework the operator evaluation and re-evaluation language and that type and capacity be put back into the rewrite of 1427. This would result in operators having the choice of being certified by type and capacity or by type only. ACCSH also recommended that OSHA clarify whether a trainer be certified or certified and qualified and that OSHA develop some reasonable definition of who the controlling contractor would be on the job site.

I’ve always been a little skeptical of OSHA and its control in the workplace. However, after attending the ACCSH meeting I have a lot more respect for OSHA and what it does to protect workers. I was also very pleased with the meeting and have great admiration for the members of the ACCSH committee. Some of these members might not have even known what a crane was when the meeting first started, but they came up to speed very quickly and were very astute to the issues being presented. They made appropriate motions and recommendations to OSHA regarding the most important points of the proposed draft.

So this is what we can be assured of: OSHA is going to require that operators be evaluated on a periodic basis with signed documentation by an evaluator. There will be more stringent training requirements which will have to be documented along with the periodic evaluations. In other words, people will have to attend more of a professional type training program which covers the topics outlined in the proposed draft. It was also expressed that OSHA would like to get all of this done by year’s end. So now we just have to wait for OSHA to do their work and present another rewrite of what was previously proposed. It will then have to go through the process and hopefully by year’s end all of this can be done and this certification issue can be put to bed, and the industry can move forward in a direction that would help more men and women go home safely at the end of the work day.

– Jay Sturm

Calling all Operators: $10,000 Grand Prize!

Cranes101 and Woods CRW are teaming up again to host the Northeast #2 Regional Qualifier for the CIC Crane Operator Skills Competition! The Qualifier will be held at Woods CRW’s newest facility in Carlisle, PA on June 6th. If you’re a skilled crane operator, you should seriously consider registering! The top two winners at the Qualifier will advance to the finals, which are being held at the ICUEE Expo Demo in Louisville, KY this October. All expenses are paid for, and the Grand Prize is a whopping $10,000 dollars! Space is limited – REGISTER TODAY!

To register, please visit: http://www.craneinstitutecertification.com/news/compete/

For more information, watch the video below:

We hope to see you there!

Meeting of the Minds

Jay recently attended the Crane Institute Certification (CIC) Annual Meeting in Florida. The Governing and Advisory Boards meet once a year to discuss any changes, modifications, and updates tot he accredited crane operator program. It’s a lot of work, but they also know how to have a good time. The meetings consist of the brightest and most knowledge experts in the crane industry, truly a meeting of the minds.

Of course, all work and no play makes Jay a dull boss, so he took some breaks to work on his selfie skills while mingling with the best of the best.

jay amanada jeanie cic cranes

Jay poses outside in the Florida sun with CIC Admins Amanda Branton (left) and Jeanie Coleman (right).

jay ann cic cranes

Representing the North, Jay meets up with the always delightful Ann Campagnone, who works for Crane Institute of America in Sanford, Florida.

jay brian hope cic annual meeting 2015

A break in meetings allows Jay and Vice President of Crane U, Brian Hope, to pose for a picture.