A question posed to the Crane and Hoist Professionals group on LinkedIn asked if “Lugs” were required on underhung cranes. Most group members responded, “Yes,” because the ASME B30.11 or MH 27-1 requires it. This is not surprising because the text of many standards make them sound like they set requirements and well intended readers believe it. Let’s get technically correct:
• In the U.S., OSHA enforces the Code of Federal Regulations, for Safety and Health, with fines for non-compliance.
• In order for something to be “required” for safety and health, OSHA has to require it.
• ASME, ANSI, NFPA, NEC and other voluntary standards are only required to be followed if OSHA incorporates it.
• OSHA currently has no regulation covering underhung cranes.
• 29 CFR 1910.179 covers only top running bridge and gantry cranes.
• ASME B30.2, which is incorporated in part, covers top running cranes.
• Cranes only have to meet requirements that existed at the time of manufacture, grandfathering.
• Grandfathering and technical correctness exists until an accident.
• After an accident, OSHA can use the B30.11 lug requirement via the “general duty clause”.
• Lawyers have no rules.
• Lugs are not required on new or existing underhung cranes and employers cannot be required to install them.
• Employers must maintain a safe and healthful working environment.
• Employers can be held liable for not complying with “voluntary” standards.
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