Construction of Crane Lifting Devices
Structural lifters for use in hoisting are well defined. But we don’t see this applied in the field. We see OSB (Oriented Strand Board) and nailed together structures used for hoisting items. We see plastic bins on slings. But can these be “Structural Lifters”? Let’s take a look.
OSHA 1926.251 says:
Employers must ensure that rigging equipment:
1926.251(a)(2)(i)
Has permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load;
1926.251(a)(2)(ii)
Not be loaded in excess of its recommended safe working load as prescribed on the identification markings by the manufacturer; and
1926.251(a)(2)(iii)
Not be used without affixed, legible identification markings, required by paragraph (a)(2)(i) of this section.
Special custom design grabs, hooks, clamps, or other lifting accessories, for such units as modular panels, prefabricated structures and similar materials, shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.
The term rigging equipment is all encompassing. Everything in the chain of custody needs to be rated. It then goes on to clarify “Prefabricated structures” and cites 125% as the load test. It’s important to note that this 125% is the ASME B30.20 Below the Hook Standard. We’ll get to that.
The vagueness of the code can cause people gloss over an not recognize what’s going on. So for clarity, we need to go to the Standard Letters of Interpretation so they can clear this up for us.
In 2004 Jeff Moser sent OSHA a letter seeking clarity on the code and the applicability of ASME B30.20 to 1926.251. Their response clears up what they are referring to in 1926.251 by citing ASME B30.20 inspection criteria as being in compliance with the code. But they are not requiring the full ASME, just the rating and load testing.
Question (2): Other than for slings, it appears that there are no inspection criteria for below-the-hook lifting devices in the OSHA regulations. Would I be in compliance with OSHA requirements if I followed ASME B30.20 for inspections of below-the-hook lifting devices?
Answer
Yes. Section 1926.251 does not address inspection criteria for below-the-hook lifting devices, except for slings used in conjunction with other material handling equipment.
Under the "General Duty Clause" (Section 5(a)(1)) of the Occupational Safety and Health Act, employers must:furnish to each of [its] employees employment... free from recognized hazards that are causing or are likely to cause death or serious physical harm...
The construction industry recognizes the necessity for inspections of below-the-hook lifting devices. An employer who follows ASME B.30.20, specifically sections 20-1.3.1 through 20-1.3.7 and 20-1.3.9 with respect to inspections for below-the-hook lifting devices (other than for slings), would be considered to be in compliance with OSHA requirements.
They make it abundantly clear that the code is inclusive of Below the Hook Lifting devices. While ASME B30.20 isn’t fully codified, let’s see what the spirit of the law is.
ASME B30.20 Paragraph 1.2.2 “Construction” says “The Load Bearing Structural Components of a lifer shall be designed to withstand the stresses imposed by it’s rated load plus the weight of the lifter with a minimum desing factor of three… “ Load Bearing Structural… let’s just stop there.
We are talking about anything bearing a load in a hoisting application. Any structure bearing a load is going to be applicable here. What is the load rating of OSB? if the slings are spread out 8’ apart, it’s one number. If it’s one foot apart, it’s another. So the box that was built using nails with no instructions, how would you ever know what it’s rated for and maintain that 3:1? Is it the same rating after it rains? After it’s 10 years old? The truth is you don’t know. You are just accepting risking other people’s lives if you don’t have a data point. People are doing this with plastic bins too.
If I can illustrate a point. Someone shows up with a Coleman ice chest filled with sodas and they want to fly it up to the working deck where they just poured concrete. A person might sling it up. It’s not rated, but it will be fine, right? It’s not legal, but most people would do it. Now someone shows up with a Styrofoam Ice Chest and wants to do the same thing. You good with it? Conceptually, we lift the Styrofoam Chest on slings everyday in construction. Here’s an example. Look at the flex going on with this plastic. Do you think they have 3:1 safety leftover?
ASME B30.20 has a BTH-1 Document that lays out how these items are constructed. It cites Steel as the material to be used for Structural Lifters unless an alternative product can be shown to be stronger. And to be clear with the picture above, the BTH-1 document also cites how much flex you can allow in a structure. Look at the picture one more time.
This is the alternative to a plastic bin. This is what ASME B30.20 rated looks like.
Steel Pallet Bin with Crane Rating
The ASME BTH-1 also calls for welding as the means to connect the structures. And it’s to be done to the AWS D1.1 standards. It’s quite clear on what it means and how the engineering should be done. These lifting practices of using whatever you want because it’s on slings is simply against the law in North America.
The only way to get this to change is to be aware of the requirement. Some will complain of the cost. I was in a meeting with a large GC that screams safety publicly, but when I raised the matter, cost was an objection. It would be a $30,000 problem on many job sites. What does a death cost again? And we are talking about 8-9 deaths a year due to dropped loads. Our bin is $1044 as a one yard version. The plastic option is $350. But there is no rating. And what’s the damage if a load drops? Even if it doesn’t hit anyone, the impact in fear driven choices will cost you a lot more than the $700 extra you would spend on a steel bin.
Functionally you save money when it’s Crane Rated. You get rid of the slings. The installation of slings on and off for a lift is about 3 minutes of time lost per lift. At $500 an hour for a crane, operator and a rigger, that’s $25 per lift cycle. After the 28th lift cycle of that bin, it’s paid itself back. How many more will it do? 500? 1000 in it’s life cycle?
The code is clear in how these items are to be constructed. The only question is why this problem is allowed to continue as it is?
