The Iceberg Called OSHA
The OSHA 1910.179 Overhead and Gantry Cranes section, is only about 30 pages long. Most crane owners and crane inspectors feel confident about the requirements of these 6,698 words. Unfortunately the challenge is not OSHA 1910.179, but rather the two relatively unknown sections;
OSHA 1910.6, Incorporation by Reference
Section 5(A)(1), The General Duty Clause
Negotiating The Maze
Incorporation by Reference:
OSHA 1910.6 calls out references to 197 other consensus standards, literally tens of thousands of pages with the full force of the law. To compound this problem, each of these “consensus standards” in-turn, incorporate by reference dozens of additional standards. To know which of these 197 referenced specs are relevant is critical
The General Duty Clause:
According to the GDC, everything not specifically covered by CFR1910 is then covered by the General Duty Clause, which sets down the blanket requirement of employers to “provide a safe workplace.” The GDC is likened to Supreme Court Justice Potter Stewart’s statement about pornography; “he didn’t know how to define pornography, but knew it when he saw it.”
My 45 Years of overhead crane experience provides a reliable and economical shortcut to the relevant Consensus Standards and generally accepted shop floor best practices.
Expert Witness Experience
Since starting Overhead Crane Consulting, LLC in late 2015, I have processed several dozen Overhead Crane related projects, both engineering consulting as well as expert witness work. The expert witness work includes;
Site survey and examination
Document review
OSHA and consensus standards research
Litigation support
Report writing
Depositions
Courtroom testimony
Both plaintiff and defense
Member of FEWA (Forensic Expert Witness Association)
Board member of the Arizona Chapter of FEWA