Overhead Cranes are covered by 1910 General Industry and not by 1926 Construction right???
I can’t tell you how frequently I read something in one of the OSHA specs and say to myself, “…WOW, does it really say that?”
Today I was doing some research on the relatively new 1926 Crane CC book and just about the time I decided that it doesn’t pertain to my world of industrial overhead bridge cranes, I came across the following couple paragraphs in a book entitled “What Everyone Must Know About OSHA: Construction” by Joe Teeples and published by Mancomm. Here’s what it say about the dividing line between 1910 General Industry and 1926 Construction.
“Construction vs. General Industry
Because OSHA is responsible for ensuring the safety and health of workers in a variety of industries, it has developed regulations for each industry, such as maritime, construction and general industry (manufacturing). Often these regulations may seem to overlap, and the worker must understand what regulation applies to his or her work. OSHA considers the work being performed as the key element to this “entry argument” into the regulations. So even though a worker has a job title of construction operator, he or she may fall under the general industry rules depending on the job that is being
performed.
For example, OSHA defines “construction work” as “work for construction, alteration, and/or repair, including painting and decorating.”
The general industry standard 1910.23(c)(1) for fall protection starts at 4 ft. and requires a guardrail:
Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e) (3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides, workers can pass....
The construction standard 1926.501(b)(15) for fall protection starts at 6 ft. and allows for such protective devices as guardrails and personal fall arrest systems:
...Each employee on a walking/working surface with an unprotected side or edge which is 6 feet or more above lower levels shall be protected from falling by a guardrail system, safety net system, or
personal fall arrest system.
To continue the example, a company has one maintenance worker who fixes heating and ventilation systems and a building with a roof that is 5 ft. tall. On Monday, the worker goes to the rooftop to replace a bad motor. That work would be considered an alteration of the system, so it would fall under the construction standard.
Under that standard, the work surface must be at least 6 ft. before fall protection is needed. Two weeks later, the same worker returns to the same heating unit to change filters. However, he is not altering, constructing, painting or decorating, he is simply performing routine maintenance. In this instance, the general industry standard applies, which holds that fall protection must be provided for work surfaces more than 4 ft. above ground level—same person, same roof, same heating system, but a different regulation.”
Now I can see I just dug up a real can of worms and it’s going to take a good deal more reading to determine how this quote affects the Overhead Crane, Crane Runways, Hoists and Monorail world. I hope to have some posts for your comment in the near future.