New, Extensively Repaired, and Altered Cranes require load tests!
Question 1: Does OSHA require rated load tests for new or altered cranes?
Reply 1: OSHA requires rated load tests for new and altered cranes as stated in OSHA's letter of interpretation to Mr. Thomas Hagerty dated March 4, 1991. OSHA's standard at 29 CFR 1910.179(b) states:
(2) New and existing equipment. All new overhead and gantry cranes constructed and installed on or after August 31, 1971, shall meet the design specifications of the American National Standard Safety Code for Overhead and Gantry Cranes, ANSI B30.2.0-1967, which is incorporated by reference as specified in Sec. 1910.6.
(3) Modifications. Cranes may be modified and re-rated provided such modifications and the supporting structure are checked thoroughly for the new rated load by a qualified engineer or the equipment manufacturer. The crane shall be tested in accordance with paragraph (k)(2) of this section. New rated load shall be displayed in accordance with subparagraph (5) of this paragraph.
Additionally, OSHA's standard at 29 CFR 1910.179(k) states:
(1) Operational tests.
(i) Prior to initial use all new and altered cranes shall be tested to insure compliance with this section including the following functions:
(a) Hoisting and lowering.
(b) Trolley travel.
(c) Bridge travel.
(d) Limit switches, locking and safety devices.
(ii) The trip setting of hoist limit switches shall be determined by tests with an empty hook traveling in increasing speeds up to the maximum speed. The actuating mechanism of the limit switch shall be located so that it will trip the switch, under all conditions, in sufficient time to prevent contact of the hook or hook block with any part of the trolley.
(2) Rated load test. Test loads shall not be more than 125 percent of the rated load unless otherwise recommended by the manufacturer. The test reports shall be placed on file where readily available to appointed personnel.
The 1984 revocation of the advisory language in 29 CFR 1910.179(k)(2) did not eliminate the requirement for new and altered cranes to be load tested. Paragraph 1910.179(k)(1) requires that "[p]rior to initial use all new and altered cranes shall be tested to insure compliance with this section [1910.179]..." As rated load testing is part of section 1910.179, employers are required to perform the test on new and altered cranes in order to be compliant with the requirement in 29 CFR 1910.179(k)(1). Also, section 1910.179 contains other provisions that necessitate load testing to ensure compliance. For instance, paragraph 1910.179(n)(1) requires the employer to ensure that "[t]he crane shall not be loaded beyond its rated load except for test purposes as provided in paragraph (k) of this section [1910.179]." In order to ensure compliance with this provision as well, an employer must confirm the load rating of the crane which would require a load test.
Once a rated load test is performed, paragraph 1910.179(k)(2) requires that "[t]he test reports shall be placed on file where readily available to appointed personnel."
Question 2: What is OSHA's enforcement policy regarding rated load testing for new and altered cranes?
Reply 2: As discussed in the reply to question 1, OSHA requires rated load testing for new and altered cranes prior to their initial use to ensure that any significant problems or errors made during the repair or installation process would be revealed prior to placing the crane in operation. OSHA does not consider the provisions regarding rated load testing in the most recent version of ANSI B30.2, ANSI B30.2-2005, to be as protective as the requirements in 29 CFR 1910.179(k). Therefore, an employer must comply with the OSHA standard and cannot utilize the ANSI standard as a basis for a de minimus condition.