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For companies with crane operators in-house, we hope you have cleared the certification hurdle at this point, so the next OSHA requirement you should be focused on is operator qualification. OSHA’s deadline for operator qualification is February 7, 2019. (And in case you’re been living under a rock, the deadline for a nationally accredited certification was December 9, 2018.)
Why do we need to qualify operators who are already certified? Because the certification process is meant to be a general assessment of baseline knowledge and skills, but it can’t possibly be customized enough to make sure your operators are qualified to run every piece of equipment they run and every task they might be asked to perform.
Here’s a helpful analogy I stole from Crane Hotline Magazine’s November 9th press release: “Certification would be like passing the test to get an automobile driver’s license. Evaluation of competence would be like an employer making sure a licensed driver has the skill and experience to drive the company’s fully-loaded pickup truck on ice and snow before letting him or her drive in the winter.”
OSHA says that an operator who is not yet certified and qualified must be considered an operator-in-training and must operate only under the continuous supervision of a qualified trainer. That qualified trainer can also be your evaluator, once the time comes for evaluation.
The goals of evaluation are:
- To ensure that the operator has the ability to safely perform the assigned work
- To ensure that the operator has “the necessary skills, knowledge, and ability to recognize and avert risks in order to safely operate the actual equipment that will be used.”
The real key here is that your evaluation should be task- and equipment-specific. When you sent your operators to be certified, they took a very generic practical exam that did not take into account the typical tasks of the operator. When OSHA says that the goal of evaluation is to ensure the operator “has the necessary skills, knowledge and ability to recognize and avert risks,” what they are really saying is that your operator has the judgment necessary to do certain things on certain equipment and know what the potential dangers might be. Here are a couple of examples from OSHA’s final rule:
Example #1: When an operator appropriately recognizes that a different crane will be needed because the ground conditions at a particular job site prevent him/her from setting up the current crane at the only locations where picks with that crane would be safe.
Example #2: When operating a floating crane, an experienced operator recognizes that a change in tidal ranges could affect the boom angles at which work should be performed.
Example #3: When an operator knows to consider wind speed and direction when determining where on a jobsite air turbulence is likely and may make loads unstable.
These examples show the kinds of things that a standardized certification test can’t possibly assess. In order to truly evaluate these kinds of situations, a qualified evaluator must observe the operator on the job. Then, OSHA says, that evaluator must document the evaluation and have it available on the jobsite.
The documentation of evaluation must include the operator’s name, the evaluator’s name, the date of the evaluation, and the make, model, and configuration of the equipment on which the operator was evaluated.
We suggest that your documentation also includes the type of tasks on which the operator was observed and evaluated. That way you have a baseline with which to judge when further evaluations are needed, e.g. when the operator is assigned to do something substantially different.
How can we help? We are working on an evaluation checklist that will go beyond what OSHA requires, and we will make it available to our customers upon request once it’s finished. We will also be available to conduct operator evaluations on an hourly consulting basis for any company that does not have a qualified trainer/evaluator on staff. Lastly, our Qualified Lift Director courses in February will address this issue of setting up an in-house operator qualification program. Contact Anna for details at 303-817-5663, or anna@newenglandcraneschool.com.
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