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New OSHA Guidance - Roadmap to Complying with its Cranes and Derricks in Construction Standard

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Although OSHA implemented its Cranes and Derricks in Construction Standard (29 C.F.R. 1926 Subpart CC) back in 2010, it just now released its directive for how OSHA inspectors should enforce that rule. Multiple layers of legal review and approval, as well as revisions and challenges to the standard, contributed to the delay.

Released on October 23, 2014, this directive includes an abbreviated inspection checklist and inspection guidance for OSHA inspectors to follow, as well as recommended citation policies for complex requirements. A full-text copy of the directive can be accessed here.

Reviewing the OSHA inspection procedures will assist contractors and operators in ensuring they are compliant with the new standard, and avoid a citation if an inspection is conducted. The abbreviated check list, found at section VIII.B of the directive, provides a road map for what inspectors will be examining during a site visit. Contractors should read through this list and make sure all persons who work with cranes on site comply.

The directive also includes inspection guidance and citation policies, which identifies who should be interviewed at a site and what types of documents should be turned over during the inspection. It is important to note that the inspectors may likely be interviewing the following persons based on this directive: (1) controlling employer; (2) employer of the operator and lift crew; (3) operator; (4) equipment inspector; (5) maintenance personnel; (6) lift and A/D directors; (7) crew members; (8) riggers and (9) signal persons. Given this broad spectrum of persons who may be interviewed, in particular the non-managerial personnel, it is important to ensure proper training and crane safety compliance prior to an inspection, and certainly in the event of an accident.

The directive applies to the Federal OSHA plan only, however, State Plan States must implement enforcement policies and procedures for their Cranes and Derricks standards which are at least as effective as those in the directive. If your projects are located in jurisdictions which operate their own State OSHA plans, please check your State plan's website, or the Federal OSHA webpage to determine if there are additional requirements beyond those included in the new directive. At a minimum, however, all construction projects will be governed by the guidelines set forth in this directive. A state plan may increase the requirements, but may not require less than what is set forth here.

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