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.
Visit our online store to purchase the current ASME B30 standards.
The American National Standards Institute (ANSI) is in the process of completely overhauling its consensus standards for aerial lift platforms. Currently there are individual standard for Vehicle-Mounted, Manually-Propelled, Boom Supported, and Self-Propelled aerial lifts on inspection and maintenance. The proposed overhaul will consolidate these four separate standards into one. In addition, they are reorganizing the standard into three sections: design; operations and training; inspection and maintenance. It would appear that the A92.2 Vehicle-Mounted aerial lift standard will continue to stand alone.
Why is any of this important? Consensus standards are produced by committees of experts and are guidelines or recommended practices for aerial lift owners and users. However there are two ways they can become mandatory requirements.
1. OSHA incorporates them into their regulations making them enforceable like an OSHA Regulation.
2. OSHA invokes the General Duty Clause after an aerial lift accident to form the basis for a citation.
Currently, OSHA only has a regulation for Vehicle–Mounted aerial lifts and the ANSI A92.2 (1969) design and construction sections are incorporated into it.
To learn more, CIA offers courses in operation and inspection of all types of aerial lifts.
Read more about ANSI’s makeover.