The Lightbulb Moment

After recently attending an OSHA class at the Arizona State University, Western OSHA Education Center, the instructor used a phrase that turned on a lightbulb for me. The phrase was really quite simple, but I apparently have never focused on it before.

His statement was that the particular paragraph we were reviewing was a “Prescriptive Guidance” as opposed to a “Conceptual Guidance.” I stopped him and said I had never heard that distinction used before in the context of OSHA. He went on to explain that all OSHA rulings are either “Prescriptive” or “Conceptual.”

Prescriptive Guidance is when OSHA states that, for example, it requires warning flags on 6 ft centers or hand railings at 42 inches.

Conceptual Guidance is when OSHA says cranes have to be inspected “frequently”, but does not itemize what specifically has to be inspected nor the exact frequency. Probably the biggest Conceptual Guidance from OSHA is the General Duty Clause, in which OSHA requires employer’s to provide a safe work environment.

This concept of Prescriptive vs Conceptual Guidance hit me like a ton of bricks. As crane users and inspectors, we are constantly looking for a definitive and specific list of “do’s” and “don’ts”. In other words “Prescriptive Guidance.” The problem is that there really is no such list, at least not in OSHA 1910.179. We’re left to use are best judgment and that obviously differs greatly from person to person.

This reminds me of the time I was watching an Army General testifying before a Senate committee. After continued questioning, the Senator asked why a certain event was allowed to happen and said “…General, isn’t that just common sense?” The which the General replied,

“Senator, apparently common sense is not all that common!”

The total words written by OSHA 1910.179(j), ANSI B30.2 and CMAA 70 regarding EOT bridge crane inspections is less than 1450 words. That’s precious little guidance!!!

The only solution to this quagmire is to use the ISO9000 methodology to define your own program. In other words, to change the “Conceptual” guidelines of OSHA to your own “Prescriptive” program. As ISO requires, “Say what you’re going to do, then do what you said.” Of course, no small challenge is to establish what is appropriate for you to do… but with a little study it’s possible. Most of all, for the safety of your workers and your business, it’s an absolutely essential task.

If you don’t establish a well thought out prescriptive Overhead Crane Inspection Program, the OSHA man or worse yet, the plaintiff attorney will.

Future posts will provide a foundation for setting up your own EOT overhead crane inspection program.