Introduction
Efficient handling of materials is vital to the steel fabricating and coating shop processes. These facilities typically employ powered industrial trucks, overhead and gantry cranes, and slings to move tons of materials such as steel within the confines of a building, between buildings, and to/ from transportation vehicles. Material handling is not done without risk.
During the period from October 2015 through September 2016, metal fabricating and coating application shops received 772 citations during 522 inspections with a total penalty of $1,155,512 for non-compliance with the Occupational Safety and Health Administration (OSHA) Material Handling and Storage regulation (29 CFR 1910 Subpart N). Most notable is the non-compliance with 29 CFR 1910.178 Powered Industrial Trucks (PIT), 29 CFR 1910.179 Overhead and Gantry Cranes, and 29 CFR 1910.184 Slings. This article highlights some of the OSHA and ANSI requirements that address powered industrial trucks, overhead and gantry cranes, and slings.
Powered Industrial Trucks
OSHA’s Powered Industrial Trucks (PIT) standard defines the requirements associated with the truck’s design, construction, modifications, and illumination. The following introduces a few requirements of the standard that may be overlooked from time to time. To start, the design and construction must meet the American National Standards Institute (ANSI) standard for Powered Industrial Trucks Part II, ANSI B56.1-1969. The vehicle must bear a label stating compliance with the aforementioned ANSI standard. All modifications and additions that affect the capacity and safe operations require written approval from the manufacturer. These additions include the use of fork extensions and man baskets. Auxiliary directional lighting is required when operating a powered industrial truck in low light conditions (less than 2 lumens). Operating a PIT with a combustion engine in an enclosed area such as a shop or containment system poses the risk of carbon monoxide exposure. The Permissible Exposure Limit for carbon monoxide is 50 ppm. Since its vapor density (0.97) is slightly lighter than air, the gas rises in air accumulating in areas such as elevated work platforms. The symptoms of carbon monoxide exposure are headache, dizziness, nausea, and loss of consciousness; acute doses can cause death.
PIT Warning System Requirements: OSHA regulations do not require the use of audible or visual alarm on a PIT. It is ANSI B56.1-1969 that requires the user to determine if operating conditions dictate the use of audible or visual alarms. With that said, the use of powered industrial trucks exposes employees to struck-by, caught-in-between and crushing hazards, and the use of audible and visual alarms are a feasible method to mitigate the hazards. When one fails to employ feasible methods, OSHA can issue a violation under the General Duty Clause.
PIT Inspection Requirements: PITs are required to be inspected by the operator or other competent person daily before being put into service. Trucks operated during multiple shifts must be inspected before each shift. OSHA does not require documentation of the inspection; however, documentation of the inspection is considered a best practice. The inspection should include:
- Pre-operational inspection: fluid levels, condition of tires, forks, mast, rollover protection (ROP), hydraulic lines, seat belt, labels and name plate with serial number and load ratings.
- Operational inspection: hoisting controls, brakes, emergency brake, horn, lights, warning devices (both audible and visual), steering and accelerator linkage.
PIT Training: OSHA requires that all forklift operators receive training before operating a PIT. The content of the training is a combination of formal instruction and practical training. OSHA lists the training requirements in OSHA 29 CFR 1910.178(I). It is important that the instructor be experienced and train operators how to safely operate the PIT in the employer’s workplace. Refresher training is required at least every three years, and must include an evaluation of the operator’s performance. Evaluations should be performed during normal daily operations. Additional refresher training (formal instruction and evaluation of operator performance) should be provided upon observing unsafe operation of a PIT, a change in the work place, and when assigning an operator to a different type of PIT. The training and evaluation of each operator is required to be certificated. The certification includes the name of the operator, the date of training, name of the trainer, and model of PIT.
Overhead and Gantry Cranes
OSHA regulates overhead cranes through 29 CFR 1910.179 (Overhead and Gantry Cranes). The regulation covers general work practices, modifications, operator requirements, warning system requirements, and inspection requirements.
General Safe Work Practices/Modifications: All new overhead and gantry cranes constructed and installed on or after August 31, 1971 must meet the design specifications of the American National Standard Institute Safety Code for Overhead and Gantry Cranes, ANSI B30.2.0-1967. Cranes may be modified and rerated provided the modifications and the supporting structure are checked thoroughly for the new rated load by a qualified engineer or the equipment manufacturer. The rated load of a crane must be plainly marked on each side of the crane, and if the crane has more than one hoisting unit, each hoist must have its rated load marked (on it or its load block) so that it is legible from the ground level.
Crane Operator: Cranes are only to be operated by designated persons, trainees under the direct supervision of a designated person, or 
maintenance and test personnel, when it is necessary in the performance of their duties. A designated person is an individual deemed to be qualified to operate an overhead crane for a specific operation. Operators are required to pass a written or oral examination and a practical operating examination unless the operator provides the employer with evidence of qualification and experience. The qualification is limited to the specific type of equipment.
Warning System Requirements: Except for floor operated cranes, an effective warning system is required for cranes with a power traveling mechanism. A warning system is either a:
- Manually operated gong
- Power-operated bell, siren, or horn
- Rotating beacon, or
- Strobe light
Inspection Requirements: New, reinstalled, altered, repaired, and modified cranes are required to be inspected by a designated person (as previously defined) before initial use. Inspection procedures for cranes used regularly fall under two general classifications based on inspection intervals. The two classifications are frequent and periodic, with respective intervals between inspection defined as:
Frequent inspection is an undocumented visual inspection by the operator or other designated personnel as follows:
- Normal service – monthly
- Heavy service – weekly to monthly
- Severe service – daily to weekly
Periodic inspection is a documented visual inspection of the equipment in place by a designated person as follows:
- Normal service – yearly
- Heavy service – yearly
- Severe service – quarterly
Frequent inspection includes an examination of the following:
- Operating mechanisms for proper operation, proper adjustment, and unusual sounds
- Upper-limit device(s)
- Tanks, valves, pumps, lines, and other parts of air or hydraulic systems for leakage
- Hooks and hook latches (if used)
- Hoist ropes and end connections
- Rope of proper spooling onto drum(s) and sheaves.
Periodic inspection is an extensive process that includes the items listed under the frequent inspection and numerous other criteria listed in OSHA’s 29 CFR 1910.179(j)(3) Periodic Inspection. This inspection requires documentation and certification of the crane.
A crane that is idle for one month or more, but less than one year is inspected using the “frequent inspection” criteria before use. A crane that has been idle for one year or more is inspected using the requirements of a “periodic inspection.”
Slings
OSHA 29 CFR 910.184(c) defines the safe operating practices when working with slings. A few examples are:
- Do not use damaged or defective slings.
- Slings used in a basket hitch shall have the loads balanced to prevent slippage.
- Slings shall be padded or protected from the sharp edges of their loads.
- All employees shall be kept clear of loads about to be lifted and of suspended loads.
- Shock loading is prohibited.
- A sling shall not be pulled from under a load when the load is resting on the sling.
- Employers must not use slings without affixed and legible identification markings.
Sling Inspection Requirements: OSHA requires the inspection of all slings for damage or defects each day before use by a competent person. In addition to this requirement, each type of sling has individual inspection requirements. For example, alloy steel chain slings require the inspection to include defective welds, deformation, and an increase in length. OSHA defines the inspection requirements for each type of sling in 29 CFR 1910.184 titled, “Slings.”
Summary
Steel fabricating and coating shops rely on. powered industrial trucks, overhead and gantry cranes, and slings to move tons of materials such as steel within the confines of a building, between buildings, and to/ from transportation vehicles. Operation of this equipment can create significant workplace hazards. Training and certification of operators, routine equipment inspection, and safe use can help to avoid OSHA citations and more importantly workplace accidents.