Last week, OSHA issued compliance guidance for its Cranes and Derricks in Construction standard, CPL 02-01-057.  The Directive provides compliance guidance to Compliance Safety & Health Officers (CSHO) for inspections of construction employers operating cranes and/or derricks in construction activities.  Additionally, the Directive serves as a source of information to employers on how OSHA interprets various requirements in the standard and provides guidance to employers regarding the types of questions OSHA is likely to ask during an inspection and the documentation they are likely to request.

A section of the Directive outlines an “Abbreviated Inspection Checklist” that includes 19 items that compliance officers should consider in an inspection of any worksite with a crane.  Some of the items instruct compliance officers to:

  1. Determine the adequacy of ground conditions beneath the equipment, such as the support, foundation, cribbing, blocking, etc.
  2. Check for visible indications of repairs of the equipment
  3. Where overhead power lines are present, ask:
  • If utility owner was contacted
  • If lines are energized
  • The voltage of the power lines (if known)
  • If a work zone was demarcated and what encroachment prevention methods are being used

4. Where signal persons are used:

  • Verify qualifications and documentation (documentation can be electronic or physical copies)
  • Verify the communication system being used between the crane operator and the signal person is the one specified on the qualification documentation

5. Inspect all rigging equipment that is available for employee use (slings, chokers, shackles) for damage, wear, safe working load tags, capacity, and safety factor.

6. Verify the load chart and operations manuals are available, written in language the operator understands.

7. Verify operator qualifications and training. Observe crane operations and interview bothe the employer and the operator to determine whether the operator is competent to operate the equipment safely

8. Verify that crane/derrick and wire rope inspections requirements have been met and documentation, where required, is available.

9. Verify that qualified riggers are being used for assembly and disassembly work and when employees are within the fall zone and hooking, unhooking, guiding a load, or making the initial connection of a load to a component or structure.

In addition to the Abbreviated Inspection Checklist, the Directive provides a chart detailing what equipment is excluded from coverage of Subpart CC based on its configuration or end use and provides the appropriate standard that does regulate such equipment when it is excluded from the Cranes and Derricks standard.  For example, powered industrial trucks (forklifts) used in construction are excluded from coverage of Subpart CC when they are not equipped with a boom and hoist.  These forklifts are governed by Section 1926.600, Motor Vehicles, Mechanized Equipment, and Marine Operations.

The Directive also provides a flow chart to assist compliance officers in determining whether equipment is covered under the scope of the Cranes and Derricks in Construction standard. A flow chart specifying when articulating/knuckle-boom truck cranes used for material delivery to a construction site are covered and are not covered is also provided in the Directive.

A copy of OSHA’s Compliance Directive for the Cranes and Derricks in Construction Standard, CPL 02-01-07, can be found here.


Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.