The OSHA 1910.179 Overhead and Gantry Crane Codes and Specifications Family Tree
The OSHA 1910.179 Overhead and Gantry Crane Codes and Specifications Family Tree
The OSHA 1910.179 Overhead and Gantry Crane Codes and Specifications Family Tree
Larry Dunville
[email protected]
574-210-8612
The OSHA 1910.179
Overhead and Gantry Crane
Codes and Specifications
Family Tree
By
D. Larry Dunville
Overhead Crane Consulting.com
www.OverheadCraneConsulting.com
Overhead Crane Consulting, LLC Page 1
I. Introduction
A. Purpose Of This Document
This document was created out of my frustration with writing an article about overhead crane inspections.
Three years after selling my company, Dearborn Crane, I started my new company Overhead Crane
Consulting, LLC. I’ve spent thirty-five plus years in the crane business and the exact specifics of what OSHA
requires for the inspection of overhead cranes was about as clear as mud. I decided my new website,
OverheadCraneConsulting.com would be a great place to publish the ultimate guide to OSHA requirements
for overhead crane inspections.
After a couple weeks of research (that I thought would take just an afternoon), I discovered two overriding
facts.
1. The Givens
There are a pile “givens” that everyone in takes for granted. After a careful reading of OSHA and it’s official
Interpretations, many of these “givens” are not true, and many of the specs we assume to be gospel are
specifically excluded from OSHA 1910.179. In other word, don’t trust your “gut,” get it confirmed in black an
white.
2. The Iceberg
OSHA 1910.179: Overhead and Gantry Cranes, is the section of the massive code that covers what has come
to be called “industrial cranes.” As all documents written about engineering by lawyers, it’s vague, wordy and
just plane hard to understand.
It just can’t be that hard to get command of a document that’s less than 7000 words! The problem is that it’s
not just 7000 words, but in fact several hundred thousand words. Through the legal practice of
“Incorporation by Reference,” the lawmakers have managed to move literally hundreds of documents
outside of OSHA, under the OSHA tent. In other words, these documents that have been Incorporated by
Reference now have the same weight and force of law as the OSHA regulations.
What are the rules, where are they and who needs to know?
Drawing a Roadmap
Therefore, the purpose of this document is not a “decoder” of what OSHA means, but rather a roadmap as to
which documents are included within the purview of OSHA 1910.179. As you’re about to see, it’s much, much
more than those 7000 words in the OSHA document.
If the reader finds newer versions or missed documents, feel free to notify me and I’ll update this document
accordingly. Contact [email protected] , or call me at (574) 210-8612.
A. Overview
The regulatory requirements of Overhead and Gantry Cranes can be broken down into the following four
groups (plus one of excluded documents);
1. OSHA Regulations
b) State Codes
Some states have chosen to adopt their own codes, which then supersede the federal codes. The state
codes can be very similar, or sometimes totally different.
2. Incorporation by Reference
a) ASME/ANSI B30.2: Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist
b) CMAA 70: Specifications for Top Running Bridge & Gantry Type Multiple Girder Electric Overhead
Traveling Cranes
5. Excluded Documents
“It ain’t what you don’t know that get’s you into trouble.
It’s what you know for sure, that just ain’t so.”
We’ve come to assume a lot of specs to be included in 1910.179 that really aren’t. This is a short list of the
major offenders.
OSHA has three components, 1926 Construction, 1915 Shipyards and 1910 General Industry. The
Overhead and Gantry Cranes are in section 179 of the 1910 General Industry Specifications.
Section 1910.179 is fairly short, a little under 7000 words. Unfortunately, all of OSHA is like an
iceberg. Most of the content of OSHA is hidden below the surface. Here we’ll start with the
obvious part, actual text from part 179. The following are the three paragraphs in which section
179 reaches out to include other specifications and thereby these documents gain the authority of
OSHA.
1.2) Para. 1910.179(c)(2): Access to Crane, Ref to ANSI A14.3: Fixed Ladders
1.3) Para. 1910.179(b)(3): New and existing equipment, Ref to ANSI B30.2 Overhead and
Gantry Cranes
This is a little known library of interpretations of the 1910.179 specs. To date, there are 32
interpretations available at:
https://www.osha.gov/pls/oshaweb/owaquery.query_docs?
src_doc_type=INTERPRETATIONS&src_anchor_name=1910.179&src_ex_doc_type=CW
SA&src_unique_file=CSA19901211
#1 Fitness of Operator
#2 Electrical Grounding
#3 Warning Signals
#4 Load Testing
#10 Jurisdiction
#12 Inspection
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#13 Below Hook Device
#18 Braking
#26 Braking
Periodically OSHA infractions are appealed and legal cases are brought to court that
further define or redefine the law. The following are two significant examples of such cases.
Both are OSHA appeals.
(2) 29 CFR 1915 Shipyards- this document does not apply to overhead crane inspections
(3) 29 CFR 1926 Construction- this document does not apply to overhead crane inspections
At the adoption of the Federal OSHA Statutes, the federal OSHA law provided for the state to adopt
their own programs. States that want to have their own programs were required to, at the very least,
adopt the federal statutes as a baseline and were then allowed to expand upon the base plan as they
wished. The states were then to submit their plans to the feds for approval.
Many of the states adopted plans essentially the same as the federal plans with a few additional
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sections to cover issues peculiar to their locale. A few states essentially started with a clean sheet of
paper and developed plans unique to that state. The list is as follows;
2. Incorporation by Reference
a) ANSI B30.2-43: Safety Codes for Cranes, Derricks, and Hoists
I Can’t find this 1943 document and believe it has been superseded by B30.2-67.
b) ANSI B30.5: Safety Code for Crawler, Locomotive and Truck Cranes
This is a primary document. It is the code upon which the 1910.179 was written. This document has
been Incorporated by Reference, from 1910.6, which means that this document has the full force of
law, as if it were directly included into 1910.179.
3 2.1.3.2 Crane Runways, Ref to AISC Manual of Steel Construction and CMAA Spec 70
5 2-1.4.2 Girders, Ref to CMAA Specification No. 70 or AISE/AIST Technical Report No. 6
6 2-1.5.2 Cab Construction, Ref to ANSI A1264.1 Guard railings and ANSI/SAE Z26.1 Glazing
11 2-1.13.1 Electrical Equipment- General, Ref to Article 610 of ANSI/NFPA No. 70 National
Electric Code
12 2-1.14.5 Hooks, Ref to ASME B30.10 Hooks
The ANSI/ASME committee has produced the following interpretations. The full interpretations
are available at,
https://cstools.asme.org/csconnect/FileUpload.cfm?View=yes&ID=19812.
2-4: Bumpers/Stops
2-5: Limits/Anti-collision
2-9: Foot-walk
2-16: Brake
2-18: Brake
2-20: Braking
2-22: Braking
2-26: Hook
2-27: Hook
2-35: Overload
2-40: Braking
2-42: Testing
2-43: Testing
2-47: Ladder
2-50: Braking
2-55: Brake
2-56: Runway
This seems to be a typo in the 1910.179 federal document. I have called CMAA in search of this
document and they have no record of such a document. It is our guess that the 1910.179 authors were
referring to the EOIC 61 spec. The precursor to CMAA was the Electric Overhead Industrial Crane
(EOIC) Association, which established a spec for overhead cranes in 1961. This spec has been
superseded by CMAA Spec 70: Specification for Top Running Bridge & Gantry Type Multiple Girder
Electric Overhead Traveling Cranes. The latest editions (as of this writing on 8/16/16) is the 2015
edition.
As it typical of most other specs, CMAA 70 includes references to other specs as follows;
1.2) Para 1.8 General, Ref to ASME B30.2 Safety Standards for Overhead and Gantry Cranes
1.3) Para 1.5 Runway Conductors, Ref to Article 610 National Electric Code
1.4) Para 1.5 Runway Conductors, Ref to OSHA 1910.304.(g)(5) & (g)(7) grounding conductor
1.5) Para 1.8 General, Ref to ASME B30.2 Safety Standards for Overhead and Gantry Cranes
1.6) Para 1.2 Building Design Considerations, Ref to ANSI ASC A14.3 Safety Requirements for
Fixed Ladders
1.7) Para 1.15 Inspection, Maintenance and Crane Operator Training, Ref to ASME B30.2 Safety
Standards for Overhead and Gantry Cranes, Chapter 2-2 & 2-3
1.8) Para 1.15 Inspection, Maintenance and Crane Operator Training, Ref to CMAA Spec 78,
Crane Inspection and Maintenance Checklist
1.9) Para 1.15 Inspection, Maintenance and Crane Operator Training, Ref to CMAA Spec 79,
Crane Operator's Manual
2.3) Para 3.2 Welding, Ref to AWS D14.1 Specification for Welding Industrial and Mill Cranes
2.6) Para 3.8.5 Operators Cab, Ref to ASME B30.2 Safety Standards for Overhead and Gantry
Cranes
2.8) Para 3.12.1 Structural Bolting, Ref to AISC Specification for Structural Joints
2.9) Para 3.12.1 Structural Bolting, Ref to ASTM A325 or ASTM A490 Bolts
3.4) Para 4.7.3 Horsepower rating, Ref to AGMA Standard 2001-D04 "Fundamental Rating
Factors and Calculations Methods
3.5) Para 4.7.2 Gearing and Pinions, Ref to ANSI/AGMA 2000-A88 "Gear Classification and
Inspection Handbook"
4.2) Para 5.1.5 Electrical Equipment, Ref to ASME B30.2 Safety Standards for Overhead and
Gantry Cranes
4.4) Para 5.2.4.1.1 Variation from Rated Voltage, Ref to NEMA MG 1-12.45
4.5) Para 5.2.4 Voltage, Ref to AIST Tech Report TR-01-1991 DC mill motors
4.9) Para 5.2.5 Operation with voltage variations, Ref to ANSI C84.1.2.4.3 range B
4.10) Para 5.2.5 Operation with voltage variations, Ref to IEEE Standard 141
4.12) Para 5.4.7.1 Control Panels, Ref to NEMA Standards publication ICS6 classifications
4.13) Para 5.4.7.4 Electrical control system, Ref to Article 610 National Electric Code, NEC
610.14(G) & NEC 610.16
4.14) Para 5.6.5 Branch circuit protection, Ref to NEC Section 610-42 Branch Circuit Protection
4.15) Para 5.6.7 Motor running over current protection, Ref to NEC 610-43 Overload
Protection
4.16) Para 5.6.8 Control circuits, Ref to NEC 610-53 Over-current Protection
4.17) Para 5.6.15 Separate grounding conductor, Ref to Article 610 National Electric Code
4.18) Para 5.6.17 Lighting, Ref to NFPA 780- Standard for installation of Lighting Protection
Systems
4.19) Para 5.8.9 Wire size, Ref to Article 610 National Electric Code
4.20) Para 5.11.1 Bridge conductors, Ref to Article 610 National Electric Code
4.21) Para 5.11.6 Grounding, Ref to OSHA 29 CFR 1910.304(g)(5) & (g)(7) path to ground
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4.22) Para 5.13.3 Voltage drops, Ref to Article 610 National Electric Code
4.27) Para 5.15.1 Remote control, Ref to see applicable ASME standards
4.29) Para 5.17.2 Below hook devices, Ref to ASME B30.20 Below the Hook Devices
4.30) Para 5.17.2 Below hook devices, Ref to SME BTH-1 Design of Below the Hook Lifting
Devices
The CMAA has a document called “Most Asked Action Alert.” This document is available at
www.mhi.org/downloads/industrygroups/cmaa/faqs/most-asked-action-alerts.pdf
Where these interpretations might not necessarily have the force of law, who better to get a
clarification from, than the people that wrote the spec?
Under the General Duty Clause, Section 5(a)(1) of OSHA, employers are required to provide their
employees with a place of employment that "is free from recognizable hazards that are causing or likely to
cause death or serious harm.
The NCOSH statement begs the question, why have any standards at all? Even though a crane may be
underhung and/or single girder (which is explicitly excluded from 1910.179), you are still subject to the
General Duty Clause.
This is not to say you’ll lose every “General Duty Clause” case, but it will require calling a lawyer, which
means dollar wise, you’ve already lost.
4. Owner’s Manual
OSHA requirement defers to specific requirements listed in the equipment owner’s manual.
5. Excluded Documents
I’ve discovered that there are a whole raft of documents that many (including myself) assumed required
adherence. The following are a few of these documents that although relevant to overhead crane
knowledge, are specifically excluded from being required by OSHA 1910.179.
b) ASME/ANSI B30.11 Monorail Systems and Underhung Cranes, is specifically excluded per OSHA
Interpretation #28
c) ASME/ANSI B30.16 Overhead Hoists, is specifically excluded per OSHA Interpretation #28
d) ASME/ANSI B30.17 Overhead and Gantry Cranes (Top Running Bridge, Single Girder, Underhung
Hoist) is specifically excluded per OSHA Interpretation #28
e) CMAA Spec 74, Specifications for Top Running & Under Running Single Girder Electric Traveling
Cranes Utilizing Under Running Trolley Hoists
C. Summary
1. Tip of the Iceberg
OSHA compliance is much more than it appears, more than just 1910.179. In fact dozens of referenced
documents that because of “Incorporation by Reference” have the full force of law of the OSHA document.
a) Primary Documents
These are the documents you can’t ignore. Most of all, don’t be lured into thinking that the OSHA doc
is all you need, or you’ll fall in the trap of “Incorporation by Reference.”
b) Secondary Documents
(1) OSHA Interpretations
c) Tertiary
(1) All other documents listed above
3. Exclusions
Although underhung cranes, single girder cranes, monorails and underhung hoists are technically free of
OSHA inspections requirements, due to the General Duty Clause and the likelihood of being chased by a
Plaintiff’s lawyer in the event of an on the job injury, pursuing the OSHA 1910.179 guidelines for all cranes
should be considered.
D. Disclaimer
Neither Overhead Crane Consulting,LLC, its officers, directors or employees have any other participation
in the development and preparation of the information contained in the Specifications. All inquiries
concerning this document should be directed in writing to D. Larry Dunville, Overhead Crane Consulting,
12666 Highland Shores Drive, Sawyer, MI 49125 or [email protected].
Users of this document must rely on their own engineers/designers or a manufacturer representative to
specify or design applications or uses. These Specifications are offered as information and guidelines
which a user may or may not choose to adopt, modify or reject. If a user refers to, or otherwise employs,
all or any part of these Specifications, the user is agreeing to the following terms of indemnity, warranty
disclaimer, and disclaimer of liability. The use of these Specifications is permissive and advisory only and
not mandatory. Voluntary use is within the control and discretion of the user and is not intended to, and
does not in any way limit the ingenuity, responsibility or prerogative of individual manufacturers to design
or produce electric overhead traveling cranes which do not comply with these Specifications. These
advisory Specifications provide technical guidelines for the user to specify his application. Following these
Specifications does not assure his compliance with applicable federal, state, and local laws or regulations
and codes. Caution must be exercised when relying upon other specifications and codes developed by
other bodies and incorporated by reference herein since such material may be modified or amended from
time to time subsequent to the printing of this edition.
E. Document Version
1. R0, 8/18/2016