C-DAC Proposed Rule Crane Committee Response Comments Form by Fzd4JI


									                    C-DAC Proposed Rule
           Crane Committee Response Comments Form

Please type your name in the gray box below.

The OSHA proposed rule section text and rationale follow. At the
end is the space for your comments.

Please comment on any or all sections, save the document, and
return to Erin (esantiago@asce.org) by Nov. 18 or before.


Section 1432: Multiple Crane/Derrick Lifts
1926.1432 Multiple Crane/Derrick Lifts.

Proposed OSHA Language

     (a) Plan development. Before beginning a crane/derrick operation in which more
than one crane/derrick will be supporting the load, the operation must be planned. The
planning must meet the following requirements:
     (1) The plan must be developed by a qualified person.
     (2) The plan must be designed to ensure that the requirements of this subpart are
     (3) Where the qualified person determines that engineering expertise is needed for
the planning, the employer must ensure that it is provided.
     (b) Plan implementation.
     (1) The multiple-crane/derrick lift must be supervised by a person who meets the
criteria for both a competent person and a qualified person, or by a competent person
who is assisted by one or more qualified persons.
     (2) The supervisor must review the plan with all workers who will be involved with
the operation. 

OSHA Rationale

      This proposed section lists additional requirements for operations involving
multiple cranes and derricks. It addresses hazards arising from operations that use
more than one crane/derrick to lift a single load. This section evolved from the
Committee's concern that such operations involve an additional level of risk due to
their higher degree of complexity. Specifically, the number and type of factors that
must be accounted for, the difficulties associated with closely coordinating the
movement of the multiple cranes/derricks, and the likelihood that such lifts are
typically outside the normal routine for most employers, combine to create this higher
level of risk. Consequently, the Committee agreed that such lifts need an additional
level of planning and expertise over that required in routine operations. This section
would require development and implementation of a plan by qualified persons, which
would result in proactive decision-making and greater awareness and caution during
multiple-crane/derrick operations.
    Currently, Subpart N, through incorporation of section 5-3.2.31 of ANSI B30.5-
1968, addresses multiple lifts as follows: ``When two or more cranes are used to lift
one load, one designated person shall be responsible for the operation. He shall
analyze the operation and instruct all personnel involved in the proper positioning,
rigging of the load, and the movements to be made.'' As discussed below, this proposed
rule also requires supervision of the operation and instruction of personnel but, in
addition, specifies qualifications that the person who supervises the lift must have
and contains additional provisions to ensure safety.

Paragraph 1432(a) Plan Development
    The purpose of the proposed requirement for a plan is to help ensure that the
hazards involved with a multiple lift are identified and eliminated. These hazards
include, but are not limited to, load slipping and unintended load shifting. Such
hazards can be minimized by a plan that addresses elements such as the capacity of the
cranes/derricks relative to load distribution (throughout the lift), load rigging,
load travel (from start to finish), and communication. The Committee discussed several
specific methods of addressing these hazards, but in view of the wide variety and
circumstances of such lifts, determined that a plan-based requirement would be most
appropriate and would be effective in reducing the risks associated with these
    Proposed Sec. 1926.1432(a)(1) would require that a qualified person develop the
plan. Because of the inherent complexity of these operations, Committee members
believed that it is necessary for a person with a high degree of knowledge and
experience to develop the plan; otherwise, there is a significant likelihood that the
plan would be ineffective in addressing the hazards. Therefore, the Committee
determined that the plan developer would need to be a qualified person.
    Proposed Sec. 1926.1432(a)(2) would require that the plan be designed to ensure
that the requirements of this Subpart are met. This provision emphasizes that all
applicable requirements in the proposed standard must be met when performing multiple
crane/derrick lifts, in addition to the specific requirements set forth in this
section. The Committee believed that it was important to emphasize this in the plan to
help ensure safe multiple-crane/derrick lift operations.

Paragraph 1432(a)(3)
    Proposed Sec. 1926.1432(a)(3) would require engineering expertise to be provided
by the employer whenever the qualified person determines that it is necessary. In the
view of the Committee, some, but not all multiple-crane/derrick lifts need to be
planned with engineering expertise so that the lift can be performed safely. The
Committee believed that it is not practical to set criteria in this proposed rule for
identifying which lifts need such expertise.

Paragraph 1432(b) Plan Implementation
    Under this proposed paragraph, the employer would be required to take specific
steps designed to ensure that the decisions and precautions built into the plan are
effectively implemented.
    Proposed Sec. 1926.1432(b)(1) would require supervision of plan implementation by
competent and qualified persons, or by one person who meets the definitions of both.
The Committee believed that, especially in light of the inherent complexity of these
operations, it is essential that a person (or team) with sufficient expertise and
authority oversee the implementation of the plan. Supervision by a person or team with
the attributes of both a competent and qualified person would ensure not only that
potential problems are identified, but also that the person in charge of oversight
will have the authority to correct anything that is amiss. For a detailed explanation
of competent and qualified persons, refer to the preamble discussion of proposed Sec.
1926.1404(a),Supervision--competent-qualified person.
    Proposed Sec. 1926.1432(b)(2) would mandate that the supervisor review the plan
with all employees who will be involved with the operation before lift operations
begin. This would typically involve the signal person, rigging crew, crane operator,
and sometimes laborers, who would all meet to make certain that everyone understands
the plan and how the operation will be conducted. The Committee believed that it is
important for employees to know how the plan will work, including their
responsibilities and the responsibilities of others, to help ensure that the diverse
aspects of the operation will be coordinated. 
Committee Member Comment

1. Please either accept proposed language by typing “Accept” by placing your cursor in the gray box
below and begin typing or
2. Type your suggested revision of the text (meaning a whole sentence or the whole section retyped as
you would want to see it)
3. Save your changes and e-mail back to Erin (esantiago@asce.org)

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