Here is some valuable information…

Many questions have been raised regarding the actual requirements for Overhead Hoist and Crane Maintenance & Inspection Training, as well as requirements for Operator Training.  Crane Training USA felt it important to provide some actual code information, as well as OSHA code interpretation and OSHA citations & notifications to clarify training requirements. We can’t give definitive training requirements without discussing, for your understanding, the OSHA Code of Federal Regulations CFR-29 LABOR.

The Code of Federal Regulations CFR-29 (OSHA) contains what is known as “The General Duty Clause”, stating the following:  “1903.1 Purpose and scope. The Williams-Steiger Occupational Safety and Health Act of 1970 (84 Stat. 1590 et seq., 29 U.S.C. 651 et seq.) requires, in part, that every employer covered under the Act furnish to 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 Act also requires that employers comply with occupational safety and health standards promulgated under the Act, and that employees comply with standards, rules, regulations and orders issued under the Act which are applicable to their own actions and conduct.”

Further it goes on to state, OSHA 1910.6 Incorporated by Reference.  “(a) The standards of agencies of the U.S. Government, and organizations which are not agencies of the U.S. Government which are incorporated by reference in this part, have the same force and affect as other standards in this part.  Only the mandatory provisions (i.e., provisions containing the word “shall” or other mandatory language) of standards incorporated by reference are adopted as standards under the Occupational Safety and Health Act.”

In order to completely understand the requirements of the Code of Federal Regulations (OSHA), in relationship to Overhead Hoist and Crane Maintenance & Inspection Training and Operator Training, it is important to understand some definitions, as provided by OSHA.

• “1910.179 (a)(35) Designated:  Means selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties.”

• “1910.179 (b)(8) Designated Personnel:  Only designated personnel shall be permitted to operate a crane covered by this section.”

• “Section (I)(3)(i) Any unsafe conditions disclosed by the inspection requirements of paragraph (j) of this section shall be done only by designated personnel.”

Incorporated by Reference, an American Society of Mechanical Engineers (previouslyANSI) ASME B30.2 and ASME B30.17 state an additional definition as follows:

• “Qualified Person:  A person who, by possession of a recognized degree in an applicable field or a certificate of professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems relating to the subject matter and work.”

If you will note in the OSHA code, it describes designated as being, “selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties”. The emphasis is on the word “qualified”, as in “qualified person” in the above references and others in the ASME/ANSI code.

Additionally, you will find in the OSHA standards, interpretations and compliance letters, that OSHA personnel have addressed these, and it is important to understand the interpretations when making your decisions for Overhead Hoist and Crane Training requirements.  Interpretations are as follows:

•  “Competent Person:  Means 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 Must Have Authority: To take prompt measures to eliminate hazards at the work site and have the experience to be capable of identifying these hazards.” For this reason, a competent person is required under the inspection requirements in OSHA CFR 29.

•  “Successfully Completed Training Instruction: Employees who have successfully completed their required instruction “shall” be certified by their instructor or the head instructor, as having successfully completed the necessary training.  A written certification shall be given to each person so certified.”

•  “Certificate Of Attendance:  The instructor must assess whether the individual has achieved the training objectives set forth and certify that individual accordingly. While it is ultimately the responsibility of the employer to ensure that employees are adequately trained, the employer relies on the professional judgment of the instructor in making the determination as to whether the employee has completed the necessary training successfully.”   

• “Refresher Training:  Was developed to ensure that employees understand and adhere to the current operating procedures.

“OSHA believes that, due to wide variations in complexity of operations, and to the differences in experience and skill levels of employees, employers need to use appropriate methods, such as written tests, oral examinations, simulation exercises, etc., to ensure that employees understand the training they have received…  While OSHA finds it regrettable that anyone would lose his or her job as a result of failing a single test, they believe that it is essential that only those who have demonstrated the ability to do their jobs safely be allowed to work…”

Crane Training USA strongly advises, in light of the Code of Federal Regulations, Interpretations, and Incorporated by References, that initial training be a requirement for Overhead Hoist and Crane Maintenance & Inspection, Operator, and Supervisor personnel, then follow up with refresher training sessions at least every two years.

We hope that we have answered some of your questions regarding Overhead Hoist and Crane Training requirements.  Crane Training USA can provide 100% of your Overhead Hoist and Crane Safety Training, compliant with all codes and regulations.