By Jeff Johnson06 September 2017
The author, Jeffery Johnson, owner of Professional Service & Repair, is an advanced level Mobile Crane Inspector, NCCCO Certified Mobile Crane Inspector, Overhead Crane Inspector, Certified NDT Inspector (Level II (VT, MT, PT), ASE Certified Master Automotive and Heavy Truck Technician and Certified Rigging and Signal Person Trainer. He is a member of SAE, International and the ASME.
As a crane inspector the two most common questions I am asked are “did my crane pass?” and “are you going to shut me down?” The answer to both questions can be simple or complex, and may generate other questions depending on the circumstances. So let’s discuss each one.
Did I pass?
There is not a “pass or fail” on an inspection. OSHA in both 1926 construction standards and 1910.180 general industry standards does not have a maximum number of deficiencies that a machine may have. It is the responsibility of the machine owner to repair all deficiencies on a machine after being informed of them by the qualified person performing the inspection or by the operator during his or her inspection. A customer or job site may have additional requirements including and above the OSHA requirements.
I have a deficiency. Do I have to shut the machine down?
That depends. OSHA requires the machine to be shut down or placed out of service if a deficiency constitutes a safety hazard. Therefore, each deficiency must be examined on an individual basis to determine the level of hazard it represents. Many inspectors will list an item that is not a safety hazard but should be monitored for further evaluation as a “recommendation.” While OSHA doesn’t specifically use the word “recommendation” in the standards, it is generally recognized as not constituting a safety hazard but should be monitored.
Who can determine the level of hazard?
The determination if a deficiency is a safety hazard is made by the qualified person performing the inspection or by the operator during his pre-operation, monthly or periodic inspection.
What constitutes a shut down/out of service?
When a machine is found to have a deficiency that constitutes a safety hazard, the employer must remove the machine or a specific function must be placed on out-of-service status. If the machine is being taken out of service, a tag must be placed in the cab stating that the equipment is out of service and is not to be used. If a specific function has a deficiency, a tag must be placed in a conspicuous position stating that the function is out of service and not to be used.
What about inspection after repairs are made?
After repairs are completed the employer or owner should sign off on the inspection report indicating that the deficiency has been repaired. It is a best practice to have a copy of the repair documents filed with the inspection report.
What about an inspection decal?
I am often asked if the machine can operate without an inspection decal. The decal is merely a reminder of who performed the inspection and when it was performed. The inspection document itself is the governing document that will be required in the event of a field inspection by OSHA or a client.
How frequent should inspections occur?
Another common question is the frequency which inspections should occur. This falls into several categories. We will cover a brief definition:
Inspection and functional testing are required after modifications by a qualified person (includes all modifications that involve a crane’s safety device, operational aide, critical part of a control system, power plant, braking system, load hook or in use operating mechanism or capacity.) Documentation is required.
Repaired or adjusted
Post inspection repairs should be performed prior to placing equipment back in service by a qualified person who will determine that repairs meet equipment manufacturers’ criteria, and in circumstances that manufacturers criteria is unavailable or inapplicable determine if a registered professional engineer is needed to develop criteria. Documentation is required.
A qualified person must perform upon completion and verify that it is configured in accordance with manufacturer equipment criteria. Documentation is required.
A competent person performs a visual inspection prior to each work shift beginning. Documentation is required.
A competent person perform a wire rope inspection and documentation is required and retained for three months. Any deficiencies that were identified on previous inspections and not determined to be a safety hazard should by reviewed during the monthly inspection to determine if wear or damage has progressed.
At least every 12 months and must be performed by a qualified person and functional testing must be included. Disassembly is required as necessary to complete the inspection.
As you can see there is no simple answer to the question of frequency. The simple answer is if a safety hazard is present the crane must be shut down. If not a safety hazard, it must be documented and monitored.