Understanding ASME B30.2-2022 Updates: Interpreting New Overhead Crane Standards

Intro

So this guy was calling me ’cause he had just purchased the new 2022 Standard. And he’s like, “Man, trolley rail sweeps, it says, ‘shall. ” And he is like, “Do you realize I’ve got dozens and dozens of cranes in here that don’t have trolley rail sweeps, and now I’m seeing the standard and it says they shall be included. So does that mean I got to put these rail sweeps in?”

For your own safety, you are reminded to stand behind the yellow line.

[Ben Hengst] Welcome to Safety Factor. My name is Ben Hengst. And today we’re talking about the updates and changes made in ASME B30.2-2022. The 2022 edition took effect this year on August 24th, 2023. And as with most standards and how they’re written, there can be different interpretations of those changes. To help us interpret some of those changes, I’m joined by Tad Dunville, hoist expert and ASME B30.2 committee member. And Bobby Hamilton, Regional Service Manager at Mazzella. Guys, thanks for joining.

[Tad Dunville] Hey, thanks for having us. Bobby should have got top billing before me. He’s a little grayer and a little smarter than I am, probably.

Meet the ASME B30.2 Overhead Crane Experts

[Hengst] Would you guys mind just briefly introducing yourself? Tell me a bit about your experience in the overhead crane industry and what perspective you bring to help interpret these changes in ASME B30.2?

[Bobby Hamilton] Yeah, sure. Again, I’m Bobby Hamilton. I’ve been involved in overhead cranes for probably 20 plus years. Started out as a crane operator, and then transitioned to maintenance. And we got into the crane service business and I kind of stuck with it since. Spent a lot of my time in steel mills. And I’m currently the chair of the Crane Technical Committee for the AIST. I’m also an alternate on the ASME B30.2 subcommittee. So, you know, I’m real passionate about the standards and the safety of the overhead cranes.

[Dunville] I’m Tad Dunville. I somewhat mirror Bobby’s image. I’ve been doing this for a little over 20 years and am a member of the Crane Technology Committee at AIST. And also, I am technically an alternate of B30.2, which is a great committee, really tells us a lot about how to take care of your cranes and how to design your your cranes.

[Hengst] So there’s a lot of big changes that took effect in the 2022 edition. So, in your guys’ opinion, what are some of the biggest, most important changes that you’ve seen?

The Legality of ASME B30.2-2022

[Dunville] Maybe we get a little background as to what went into effect. B30.2 is a consensus standard, and that means that it’s not just crane guys and it’s not just federal regulators. In fact, I don’t know that we have any federal employees. Bobby, you might correct me on that. But a consensus standard is designed to have people from all different parts of the crane ecosystem or lifecycle: owners, managers, designers, builders, fixers. And so that’s what gives it a lot of credibility, and that’s why OSHA has included it by reference, which gives it something like the force of federal law. What really has the force of federal law is the 1967, I believe, version of this. Every update since then has some great clarifications. The 2022 version is the latest and greatest, both figuratively and literally. I think we’ve put a lot of time into it and hard work and some of the guys on the committee like Jody, who was our recently stepped down chairman, just a wealth of knowledge and experience. So… And, Bobby, correct me if I’m wrong, but I feel like anybody that flaunts the rules in the latest edition will find themselves in just as much hot water, whether in terms of bodily harm and health or financial damages.

[Hamilton] Yeah, and I think that those are all great points. And just to add to that, you know, Tad mentioned the 1967 ANSI standard, which is actually what became the 1910.179 that we’re all familiar with now for double girder or top running overhead bridge cranes. To give you an example of the relevance of the ASME standard, since 1971, when 1910.179 was enacted, it’s been amended about seven times and it didn’t have any real significant changes in it. But the ASME B30.2, it’s updated every five years. And not only is the safety culture of the companies changing, but the technology’s changing as well. You know, in 1967, VFD drives weren’t a big, you know, it wasn’t a technology, radio control wasn’t a big technology. So ASME not only stays up to date on the safety trends that are impacting overhead crane users, but also the technology that’s advancing as well has a big impact on it as well. So it is incredibly relevant. And like Tad said, it is incorporated by reference the design standards. It carries the full weight of the law with OSHA. So it’s very important that if you’re a manufacturer and you have overhead cranes, that you know what the changes are, you’re adhering to them because it protects the safety of your employees and it it will protect you and keep you from getting costly OSHA violations.

Emphasizing Safety to Protect Profits

[Dunville] That’s a great point. We have to ask ourselves why are we here at the risk of sounding like a former vice presidential candidate that got on national news and said, “Who am I and what am I doing here?” At one time, perhaps 20, 25 years ago, it was the Wild West, right? And we looked at rules like this and said, “How do I get around ’em and save a little bit of money?” But at this point, we’ve found that that safety is profitability. When a crane breaks, you either have repair costs, you have productivity issues, or you have health issues, life and limb and injury and death. And so we’ve found, empirically proven, that number one, your insurance, regardless of whether or not you care about the guy you just killed or cut his toe off, your insurance costs will go up. It’s a loan. You will see an increase in premiums to the point that you pay back the injury cost with interest. So think of it as a loan and a usurious one at that, it’s going to cost you a ton of money. And so number one, safety is profitability. Number two, when you look at if the crane can’t ship or unload or load trucks and rail cars or machinery, the factory isn’t functioning and they’re losing money to the tune of hundreds of thousands of dollars an hour. So, why are we here? We’re not here to slap wrists and be like the nuns in the Blues Brothers that are always slapping Jake and Elwood around just for discipline purposes. We’re here because safety is profitability and good cranes are profitability. So at the end of the day, really following these rules and thinking of them as not just rules, but as a minimum in order to get your facility safely working and productively working, this is a profitability thing all day long.

What changes are in the ASME B30.2-2022 standard?

[Hengst] So, not everybody has access to ASME B30.2, a copy of it, so let’s try to bullet point some of the big changes that you guys saw that really stood out to you as you went through it.

[Dunville] Bobby, what do you think? There’s… I remember talking a lot about, and I’ve seen a lot of, you know, if you read the new standard, there’s a lot of discussion about what is a crane and what is not a crane in terms of what is below the hook, what is a lifter versus what is the bottom block? And and it seems that there must have been a lot of confusion in the last few years as to, “Do I consider my lifter part of the crane?” “Is it weaved in or is it a a temporary thing?” “Is it a shift long lifter?” We focused a lot on that, and I think that that indicates that there’s a lot of end user gray area. How do you feel about that?

[Hamilton] Yeah, I think you’re right. I, you know, I think it goes back… And I’m going to add that in in addition to that very subject, I think there’s some confusion on a lot of the standards that are in this because, you know, folks aren’t really, they’re not really understanding it, they’re not reading it, they’re not asking questions, they’re not consulting experts to understand what all the details are of a lot of the issues. So, you know, there’s the design standards changes, and there’s a handful of those, and then there’s some load testing changes. There’s a medical and vision requirement addition. There’s some additional verbiage for the operator in regards to moving the load and even the responsibilities of signal persons. So, yeah, Tad to your point, in addition to, you know, what is a crane, what does that mean, what does that look like? You know, there’s other parts too. You know, if you’re doing it, you know, making a lift and you have a signal person, what is the signal person’s responsibilities? Who’s going to really truly direct the load, the movement of the load? Who does that? What does that look like, right? And you made a good point. You know, like, below the hook lifting devices, can we test them on, you know, can we test the load-

[Dunville] The limit switch?

[Hamilton] Yeah, with the limits, can it be on the hook when we’re testing the limit switch? You know, so those are some of the things that were definitely addressed and when we have a clear direction on what we should be doing going forward.

Who’s responsibility is it to understand the changes in ASME standards?

[Hamilton] So, yeah, so that’s a good point, but I just want to reiterate, it’s the end user’s responsibility to know and follow these standards so that they’re, you know, they’re keeping their employees safe and they’re keeping their facilities, you know, functional and producing product.

Interpreting Gray Areas in Crane Standards

[Dunville] So, another piece of background I think we should talk about to this is, clearly, there’s been a lot of gray area, and one of the biggest ones that we addressed in the latest standard was, what is a crane versus what is below the hook and is it a shift wide lifter versus just a temporary one lift lifter? When you have a gray area like that, when you’re an end user, unfortunately, despite the fact that cranes can cost hundreds of thousands of dollars and are very large, and it’s very easy to hurt somebody, really, in the grand scheme of things, the licensing and and expertise requirements to operate or maintain them, despite the fact we’ve added to them, are somewhat minimal compared to an automobile, a semi-truck, God knows, there’s something like a ship or a train, which are all similar orders of magnitude of how large they are, how serious they are to operate and dangerous they can be, and how, on the flip side, how useful they can be to your bottom line. And so if I am a purchasing agent or a maintenance guy or an engineer or an end user, or anybody else for that matter that touches a crane, and that’s important it can’t just be those guys, what do I do when I have a gray area? You know, number one, you start with federal law, OSHA 1910.179 and also any state law. So, Ben and I had an offline discussion recently about the states of Washington and California have state-based OSHA’s, as does Michigan, that are a bit more riggerous than the federal rules. But you can also write or call your service company such as Mazzella that’s doing work in-house, you can write or call the manufacturer of the equipment. And what that does, number one, it can get you a fast answer because myself as a crane and hoist guy and Bobby as the director level employee of Mazzella, we want your business. And so we’re not going to say, “Oh, go look it up.” We’re going to say, “I do this all the time. Hang on, let me pull out an applicable code section and give you some direction if not a firm answer.” Because we’re here to help. We do this every day. We want to earn your business. So the shortcut is to call your service company, call the OEM, even call a friend in the business because we’re here to help and we want to provide the shortcut answer. If that helps you, it helps us to work with our customers and have a better relationship and promote safety and productivity. You can also write to a number of these bodies, whether it’s OSHA, ASME, AIST, you can write these people with your questions and they will provide you with an answer for free as opposed to if you hired a lawyer for a couple hundred dollars an hour, who would give you a fast answer, but it would cost you and it would be non-biased. If you write AIST or ASME or OSHA, they will give you a non-biased, very good factual answer. The problem is, it’s going to take a while and it’s a garbage in, garbage out situation. So if you don’t document your situation well and you just say, “Hey, I got a load on the hook and I need to know about X, Y, Z,” it might take 90 days to get an answer back and you might not get the answer you like, and especially if you haven’t documented your situation very well. So here’s a great example, is we addressed what is a crane and it says, you have to take below hook devices off to test the limits, unless they’re shift wide. So if you’re describing this scenario, you would want to discern between, “I have a coil grabber under my hook that I use for every lift all day” versus “I have a sling that we don’t even know where it came from that was hanging from the lifter when we walked in this morning, and we need to test the limits. Should we pull that sling off or not?” And then, okay, that’s good information for those non-biased regulatory bodies to have because they can provide a better answer. But again, it’s going to take 90 days plus to get your answer back depending on who the body is, and you may not like the answer. And then now that you have that answer, that’s a pretty finite hard answer of, “Okay, that’s the rule. We have to do that unless we want to, you know, now figure out how this doesn’t really apply to us.” So it’s always really helpful to know what your options are when trying to figure out these gray areas,

[Hengst] Any updates that might change day-to-day operations as people who already have overhead cranes and use them every day? Anything that they might need to know.

[Dunville] Bobby, what do you think about the signaling issues? I mean, that’s day to day, and I think we look at signal people as not crane guys, right?

New Guidance for Overhead Crane Signal Persons

[Hamilton] Yeah, I think that’s a good one to talk about. So, yeah. So ASME has actually added a section. It’s 2-3.3.6, and it outlines the responsibilities of signal persons. That’s new to the standard. There’s great guidance that, you know, that crane owners, operators should be adhering to, to make sure that their lifts are safe. So I would definitely recommend that, you know, obtain the latest edition of this and then that you looked this over and that you implemented it at your facility. But it definitely has answered a call to have some, you know, clarification on what this looks like and how it should work to prevent some of the injuries that have occurred in our industry over the years because we didn’t really have an understanding or guidance on what the signal person’s role is, what’s their responsibility. So I think that’s a great one that we should definitely recommend that everybody takes a look at.

[Hengst] So, is this actually requiring that now if you’re operating an overhead crane, you need to have a signal person to be signaling, or is it just kind of outlining the responsibilities of who the signal person is, what they’re doing and everything like that?

[Hamilton] Yeah, so what it really does is it outlines the responsibilities if there’s a signal person that’s going to be needed to manage a load handling activity. That’s really what it does. The best example I can give you is there’s, you know, there’s, really, there’s two modes for a crane when it’s operating. It’s in a maintenance process or it’s in a production process. And this certainly doesn’t apply to all situations. But generally speaking, in a maintenance situation, you’re picking a piece of equipment, you’re replacing a piece of equipment, you, know, there’s going to be a signal person there to direct that. So, you know, there’s really good guidance on making sure that there’s a good communication between the signal person and the crane operator. The crane operator needs to understand the signals so that they don’t move inadvertently the opposite direction, which could put someone in a line of fire to be injured. And the other example is, there is there are production cranes where the operator may be in a warehouse and there’s nobody in there and they’re picking up and moving material that’s being brought in, maybe it’s on a conveyor or it’s on some kind of a belt, so, you know, there’s not really a standard that says you have to have a signal person. So in that instance, the operator’s going to make the move, they’re going to make the pick, you know, on their own. So again, this goes in hand in hand with the, you know, the section that’s already included in the standard for the responsibility of riggers in addition to signal persons. You know, they’re real good guidance on what riggers responsibility are, making sure that it’s, you know, the load doesn’t shift, they got the right equipment to make the pick. So, I think it’s really good material. So in those instances where you do have to have that signal person, this great clarification so that it clears up the confusion on what the signal person’s responsibilities are.

It’s Not Just About the Cranes Anymore

[Dunville] So you make a good point there. and we’ve got the signal person requirements, we’ve got the new medical and vision criteria requirements, we’ve got a few more additional pieces about what it takes to maintain cranes, and what this I think recognizes overall is that it’s more than just the crane. A lot of times, we see the injuries being people near the cranes, outside contractors that have been hired to fix something on or near the cranes. I think people are finally starting to realize it’s more than the crane. It’s the people around the crane that are just as much in harm’s way. And I mean, look, it’s no different than when you have a train track, right? The train comes by at 80 miles an hour. We have lights, we have sounds, we have bells, we have bright yellow and red gates and pylons warning us, here’s a large dangerous thing that’s hard to stop. And we’re finally realizing with cranes, here’s a large dangerous thing that’s hard to stop and we need to have some kinds of standards and responsibilities written down for those people that are near it so that we don’t get hurt. What do you think, Bobby? I mean, the majority of injuries on or near cranes, are they day-to-day operators and people or are they people that are just touching it randomly or, you know, procedurally out outside the norm?

Complacency Can Lead to Incidents

[Hamilton] Yeah, I think that’s a good point. I think from what I see on my side, I think a lot of the incidents actually happen to seasoned, experienced operators or maintenance people. I think they’re the ones that do it the longest. And I think the reason for it is, I think they get complacent. I think complacency is putting them in these hazardous situations. And to go back, I think, on, kind of touch on what you said, Tad, you know, there is the verbiage now the management, the owner user shall establish medical and vision criteria, you know, if required for persons who operate a crane. So what’s happening in the industry is that the days of just bringing somebody in and saying, “Hey, here’s the crane, here’s the radio transmitter, go run it.” Those days are over. We’re getting… We’re training. We’re making sure that the folks don’t have the medical issues or vision issues that could impair their ability to run the crane. There’s times when, you know, there a lot of these places that it may not be well lit, it may be, you know, the flooring’s uneven, there’s oil, there’s debris, you got to climb up and down stairs and you’ve got to be able to physically meet those requirements to be able to safely operate that equipment. If an individual were to struggle with any of those tasks, that could impair their ability to run the crane and that puts people in danger. So I think that, you know, again, it’s good that the owners, the, you know, users, you got to have a training program, you got to be training your operators, you got to be… They got to understand what their frequent inspection obligations are at the beginning of the shift. And they got to understand, you know, how do they safely move the load, and they got to be physically able to do it. I mean, I think these are all key things and I think companies are definitely becoming more focused on this than the way they used to do it. So I think it’s a good thing that we’re recognizing this.

Vision and Medical Checks Now Required

[Dunville] So you brought up an important piece, is the medical and vision piece now is shall. And we’ve had a lot of debate over the years, what is shall versus what is should.

Clarifying “Should” vs. “Shall” in ASME Standards

[Dunville] And so if you’re tuning in at home, a requirement could say, “you should do this,” or a requirement could say, “you shall do this.” And the rule of thumb we’ve always gone by is that shall means you absolutely have to, there’s no exceptions, and should means it’s a good idea.

Costly Consequences of Non-Compliance

[Dunville] And to back up a little bit, if someone gets hurt, OSHA’s going to come in and they’re going to start writing fines. And because of the general duty clause, which says, everybody gets up in arms about general duty and it says that you have to provide a workplace free from known harms, and it pays to think about what is a known harm. And in the past, OSHA has recognized internal policy can prove that it’s a known harm. So if you have a book at the end user, whether it’s the owner’s manual or just a corporate policy that says, “You need to do x”, that’s a known harm. And so even if it’s not a shall, that’s considered a known harm. Well, the shoulds are also going to be considered known harms if someone gets help. And that’s nice and all, but those are stocking stuffers because what what happens is if someone gets hurt, the first thing that we all know what’s going to happen is OSHA’s going to come in, they’re going to do an inspection, they’re going to write a bunch of fines. The fines could be five or 10,000, 50,000, a hundred thousand dollars. And for a lot of businesses, They can figure out a way to pay that. Even if it’s a smaller family business, it was $20,000, you know, maybe we don’t go on vacation or get a new car this year, but the family business pays the fine and they keep running. If it’s a larger installation, it’s a drop in the bucket, but then you also have to consider that there’s going to be insurance costs. And like I said earlier, you’ll pay back the cost of the injury with interest to your insurance company through raised premiums. And we heard that the average workplace injury is something like a hundred thousand dollars now, because once you get the healthcare system involved, it costs a lot of money, and the average death is something like $2 million. And that’s in term of what your insurance costs are going to go up. But then you also have F. Lee Bailey or Jackie Chiles or whoever… Who’s the guy in New Orleans? Morris Bart. They’re going to sue you for $20 million. And, you know, you hope that your insurance covers that. It won’t necessarily. And so that’s… That could be an enterprise ending liability right there that could put the company out of business. So when we think about what are our financial costs of dealing with these problems, it’s not the $50,000 OSHA fine, it’s the $20 million jury award. And then on top of that, Jackie Chiles, and I hope you all remember Seinfeld, he was Kramer’s crazy attorney when Kramer burned himself on hot coffee or something like that. And he was always just absolutely hilarious on the show. But that’s… We all laugh at it. That is how plaintiff’s attorneys work, is they’re going to try to figure out the craziest thing that they can prove in court, and then they’re going to pursue it. And if it sticks, it sticks. It’s money. They literally have a fiduciary duty to their client to find those things and, you know, seek restitution for what happened to their client.

Shall vs. Should – The Debate Continues

[Dunville] They’re not just going to look at the shalls. To bring this back to ASME or OSHA, they’re not just going to look at the shalls and the shoulds and say, “Well, you know, they followed all the shalls and the shoulds are just good ideas, so we can’t really pursue you on that.” No, they’re going to push absolutely every bleeding limit when they figure out what they can sue you for. So, not only are they going to sue you for any shalls you missed, they’re going to sue you for any shoulds you missed. So when we talk about the shoulds and the shalls, we crane guys love to have these esoteric discussions about what’s a should and the shall and, you know, should we be taking down, you know, the lifters when we test the limits and is it a ship long lifter, is it just something random that was on the hook when we walked in there? Hey, look at it this way, is, what’s going to happen when Jackie Chiles comes in and sues you. You have to think a lot broader. You have to think everything. It’s not just the crane. Everything around it is part of the issue. And if it makes sense to do something in terms of safety, you should probably be doing it. And if you don’t understand or there’s a gray area, that’s when it’s a really good opportunity to call somebody like Bobby or myself and say, “Hey, I’ve got this problem and I need you to spend five minutes workshopping this with me.” Not, I don’t just want to make a split decision about, “Well, it’s not a shall so I don’t have to do it.”

Resources to Help Understand Crane Regulations

[Hengst] So speaking of giving you guys a call if you need some help, not everybody has an ASME committee member on their staff. How can people… What are the resources available to help people kind of work through these, the difficulties in interpreting these standards or understanding these standards, making sure that they’re compliant? What can companies do to make sure that they’re compliant with the new ASME standard.

[Dunville] Call Bobby. I mean, that’s a great first step. We talked about that a little earlier, but call the OEM or call your service company that is doing your inspections and repairs right now. I mean, you’re going to get the best answer from your crane company because they want to help you and they want to sell more, they want to be more productive, they want to help you be more productive. I mean, Bobby, what happens if I call you right now pretending I’m a customer, or even just a friend?

[Hamilton] Yeah, I think it’s a great point. So, I’m going to do what I can to help and direct. I’m going to, you know, share the knowledge, right? I’m going to try to help you solve your issue. So I think a great thing to do, and I would tell this to anybody who calls, whether it’s folks that have had cranes for, you know, lots of cranes and they’re very well versed in ’em, versus, you know, we got a ma and pa machine shop that just getting started. Here’s what I’m going to tell you. It doesn’t matter which end of the experience level you’re at. The OSHA 1910.179 is available online, it’s free, no charge. The standards of interpretation, there’s a whole… There’s a web link where you can access every one of them. And the standards of interpretations are those questions that industry folks are asking for clarification. And OSHA is, you know, helping to clarify you know, the confusion. So get the 1910.179, look at the standards of interpretation, read it, implement it into your policies for your crane program. My next recommendation would be go to ASME and purchase B30.2-2022. Buy that copy. You can get a printed copy mailed to your facility or you could do a PDF and download it right then as you’re ordering it. Get that standard and use it intertwined with 1910.179. Again, it’s incorporated by reference. There’s a standard of interpretation dated January 3rd, 1997. You know, read that and understand it, and then bring those standards in and develop your crane program using both of those documents. And then if you have other pieces of equipment, now, you got to remember, 1910.179 is for double girder or top running cranes. B30.2 is double girder top running and single girder top running. If you have single girder under running cranes, you want to get B30.17. Buy that standard. Implement It into your program. But I would recommend doing that. And then reach out to Tad, reach out to, you know, reach out to guys that have been in the industry for a while if you have questions about it. Like Tad was saying, we’re easily accessible. We, we don’t charge, attorneys charge, you know, fees. We don’t do that. So reach out to us and we can get you those answers, those, you know, responses real quick. And quite honestly, we want to partner with you to help you make your facility safe and keep your productivity going. That’s what we do, that’s what we’re here for, and give us the chance to do that. But that would be my recommendation to anybody if they had any questions or concerns with any of the standards.

Crane Experts are Here to Help, We’re Not Crane Police

[Dunville] So, one important point is, we are not the crane police. We are here for long-term relationships and we literally, Bobby and I and other people like us have no force of law in terms of, if you tell us something or we see something, we can give you advice, but we cannot say, “That crane has to stop with the force of law.” We can say, “Hey, it’s a really good idea to shut that thing off,” and we might even write that in a piece of paper, but we’re not the crane police. So we’re kind of like a psychologist. You can come to us and tell us your fears and troubles and what are we going to do with it other than give you good information. And we want to be with the end users and people like that long term. So we’re not going to say, “Well, you have to buy a million dollar fix or I’m calling OSHA.” Neither of those really work for us. They’re not in our motivations and we have no legal force to be the crane police. And we’re also, I would say, 80%, 90% of the people in cranes are fun, interesting people and we’re here because we like this business and we enjoy it and we’re approachable, we’re outgoing. The sense of humor on some crane guys is the size of a school bus, right? So, we’re a lot easier to approach than, you know, calling a lawyer and getting an answer that is, on record, is kind of a tough pill to swallow. I would say everybody in cranes could probably make a lot more money selling insurance or as bankers, but we’re here because we really like this business, and it’s engaging and interesting. And so as you form a relationship with your crane guy, you’ll start to realize that we’re very human, we’re very multidimensional. We’ll talk to you about cars and sports and food and fishing and, you know, it is absolutely worth coming up with a good long-term relationship with your crane guy because you’ll be better for it both technically and as a friend.

ASME Changes to Trolley Rail Sweeps Requirements

[Hamilton] Yeah, yeah. And to follow up on that, ’cause that’s all true. I agree a hundred percent. You know, crane guys, man, we’re here to help, we’re here to partner with you. You know, I received a call from one of our steel mill customers, and, Tad, you talked earlier about should and shall and what does that mean? You know, should is a recommendation, or “Do we really need to do it?” And shall, “Can I really get a citation if I don’t do, you know, what I’m directed to in shall?” And I had a guy ask me, you know, the 2016 standard, they were saying, “Hey, trolley rail sweeps is a should. That’s a recommendation, right?” Well, it is, you know, however you do, like Tad mentioned, you know, we got to be aware of a known hazard for GDC. The 2022 Standard, that has changed. So this, this guy was calling me, ’cause he just purchased the new 2022 standard. He’s like, “Man, trolley rail sweeps, it says, ‘shall.'” And and he is like, “Do you realize I’ve got dozens and dozens of cranes in here that don’t have trolley rail sweeps, and now I’m seeing this standard and it says they shall be included. So does that mean I got to put these rail sweeps in?” You know, that’s a big cost, and that’s going to impact their productivity. So, you know, so my answer is, “Well, you know, Mr. Customer, it’s incorporated by reference, it’s a design standard and you got to have ’em. You have to go back and you have to install rail sweeps now. You know, we got to have them. If something happens and there’s an injury and it occurs because maybe something was on the rail and the rail sweep wasn’t able to push it out of the way and that wheel runs up over top of the debris or whatever’s on the rail, and as a result, someone’s hurt, man, OSHA is going to come in there and they’re going to reference the 2-1.9.2 and they’re going to fine you for that, then you’re going to get a citation.” And to go back on what Tad said, now an attorney gets ahold of that. An attorney says, “Hey, the standard changed. You had to put these on, you didn’t do it. You’re liable for damage,” right? So that’s kind of how that happens, but that’s just an example. You know, really too, of a change that just occurred to 2022, the trolley rail sweeps shall be included. And then what we can do as crane experts to help partner with you to make sure you’re in compliance with your equipment.

Implementing Changes Over Time

[Dunville] So, you make a good point as to what is compliance and how do you comply. We’ve got all this knowledge about what are the new regs, and now it’s how does the rubber meet the road? And in terms of OSHA, if you don’t meet a specification, you know, if you have a written program in place for how over the next few years, and your steel mill customers a great example. If I have two cranes in my barn, I can go put rail sweeps on it pretty quickly. If I have 200 cranes, that’s a big, big problem. And so, number one, having a written document as to how we’re going to bring the cranes into compliance over the next few years is something where, you know, let’s say crane A, someone is hurt on crane A. And this is the thing, OSHA can cite you for whatever. After there’s an injury on crane A, they can go through the whole facility and cite you for whatever they want. So if they find out that cranes C, D and E don’t have rail sweeps, if you have a document that says, “Here’s the budget every 90 days for rail sweeps.” And this quarter, we’re going to do those cranes, and this quarter we’re going to do those cranes, it will at least demonstrate that you have taken time to read the standards and understand them and come up with a plan to meet them. The punishment from OSHA will be less than if you just said, “Well, you know, it’s just too darn expensive and we’re just not going to do it.” Because then, you’re actively flaunting the laws. And so, you know, number one, understanding all of these changes and having a plan, and maybe for some reason, you feel that crane F shouldn’t have rail sweeps, and I can’t think offhand of a reason why, but if you pay an engineer to come up with a justification, and so let’s take rail sweeps out of it for a minute, but safety latches on hooks are a great example. They’re required. And if you have some kind of lifter or business case or engineering case as to why you don’t need a safety latch or it might be counterproductive, wouldn’t you agree, Bobby, that in certain narrowly defined situations you could take it off?

[Hamilton] Absolutely, yeah, the greatest example of that is a ladle crane in a steel mill, right? No safety latch. What is the hazard of putting someone in a man lift or a gate that swings out over a ladle of molten steel to secure a latch, right? There’s a lot of hazard in that. Versus just let the operator take that hook and get into the lifting device on that ladle and pick it up and go. So that’s a great example of where, you know, OSHA’s not going to cite somebody for not having a safety latch in an application like that. So I think what Tad said is very, is key is, we have to show our due diligence that we’re reading these standards and we’re looking at them. And if there’s situations, you know, there might be a deviation or we may have to do something different, we got to have a documented process. We have to show where we had, we consulted with an expert. And I’m not saying that that gives us the pass to bypass or forego a standard. I’m just saying that there are instances where we can do our due diligence to make our our facilities safer by bringing in an expert to consult And let us know what we can do to go above and beyond. So, you know, I think that’s important too. But again, it really comes back to, you know, reading it and looking at it and applying it to your process and trying to understand what hazards could be there and, and really doing your due diligence. That’s just like Tad said. That’s what we have to do at the end of the day.

[Hengst] So to reinforce that, if the new 2022 standard says shall, you have to do it. But like your steel mill customer said, you might be going, “Oh my God, this is going to cost me a fortune. How am I going to afford it?” At the very least, you need to call in the experts, call a crane company, put a plan together to at least figure out how you’re going to get these changes in. Maybe it’s over a period of time, correct?

[Hamilton] Yeah, I agree. You definitely… That’s taking a proactive stance, and that’s exactly what Tad was saying. If a company, a manufacturer is proactive and they recognize that there is a hazard and they also recognize that it’s not feasible to completely remove it, in this example, installing trolley rail sweeps because they have 200 cranes. If they’re proactive and they say, “All right, we recognize the standard and we’re going to, you know, start installing these rail sweeps on these cranes at this time. Here’s the budget for it, here’s our plan, here’s what we’re going to do. It doesn’t mean OSHA’s going to give you a pass. I’m not saying that, but they’ll certainly, they will have a much better approach to that company if they’re proactive. What we see unfortunately is the reactive part of it, which is not good for, and it costs money and it’s just, it’s bad. And that would be, if you wait and let OSHA come in, and then tell you, then you recognize it. Then we have to go reactive. And that usually doesn’t end well. It results in costly fines and, you know, OSHA can come back and see where you’re… They’re going to come back and see where you’re at and how you’re doing. So I think the best thing to do is, is like Tad was saying, is proactive, due diligence and documentation. That way, you can show anybody.

Compliance is More Than Satisfying OSHA

[Hamilton] And we don’t want to just show OSHA. We want to be able to show our employees, “Hey, this is our plan.” You know, this is what we’re going to do to get our cranes in compliance ’cause, you know, the standards change. We want to be able to show this to anybody. The highest level of quality of work we can always work to is the law, right? That’s, if we meet the expectations of the law, we’ve, you know, met the expectations of the standard, but we also want to meet the expectations of the employees. You know, they’re counting… They want to go home to save to their families, their loved ones and do what they enjoy doing. And that’s what it’s all about. So we, you know, everybody, we owe an obligation to them, not just OSHA, not just lawyers, but, you know, to them as well.

[Hengst] Is there anything that you feel like we didn’t touch on that you want to touch on?

[Dunville] I think we had a a really nice discussion here today and, you know, we went over some really good broad concepts that I think will help people understand how to take care of a crane better in light of any standard, whether it’s new or tried and true. And obviously, if you have any questions as an owner about the nuts and bolts or a specific standard, you know, reach out to myself or Bobby or anybody else that you work with on these topics and we’d be happy to help you. We would enjoy that. Beats the heck out of doing spreadsheets.

How To Learn More About ASME B30.2-2022

[Hengst] Tad, how could people get ahold of you?

[Dunville] Gimme a call at 904-3186 or tdunville@gmail.com.

[Hengst] So reach out to Ted or give him a call. And as always, you can get a hold of me, Bobby, or any of our other experts at mazzellacompanies.com. Don’t forget to pop into our Learning Center. We have a ton of information on overhead cranes there, including free eBooks, courses, articles, and videos, including breakdowns on ASME B30.2. Subscribe to Safety Factor wherever you listen to your podcasts, or you can watch it on the Lifting and Rigging Channel on YouTube. Thanks for listening. Stay safe out there.