Tuesday, February 6, 2024

Nixon Era Rules not Enforced or Understood

 The beauty of AI is illustrating problems. I've spoken until I'm just exhausted laying out concepts. There are always operators who refuse to get the premise. But here's the deal, AI lays it out a bit. OSHA says that everything lifted has to be rated and tagged. There isn't an exception for placing straps below the supporting structure. The code just says rated... 

 1926.251(a)(2)

Employers must ensure that rigging equipment:
1926.251(a)(2)(i)
Has permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load;
1926.251(a)(2)(ii)
Not be loaded in excess of its recommended safe working load as prescribed on the identification markings by the manufacturer; and
1926.251(a)(2)(iii)
Not be used without affixed, legible identification markings, required by paragraph (a)(2)(i) of this section.
To put a fine argumentative point on it, this code is the beginning and the end of it. There is no other detail to consider. This has been the code since 1970 when Nixon pushed it through. The Letters of Interpretation have been repeating themselves since then. And yet guys will come back with, "It's fine to lift a wood box." Anyone ever seen a tag on a wood box signed off by an engineer?
 Let me illustrate this and see if you can end at my understanding. 

You lifting this wooden concrete bucket? I hear what you are saying that this is under tension where others are under compression. Let's put straps around it and under it. You lifting it? The wood boxes on sites held together by nails and screws with wood that is rotting day by day and getting tweaked with unknown loads and capacities are no better. You've only gotten lucky if you are lifting these. 

Some say a wood box is just fine to lift. Ok. How about this one? How many feet long is OK? How much weight? Where do we put the weight? Is it just the straps that govern the load? So four inch wide double straps good for 50,000 lbs in a basket is "fine"? You making the lift below? How much you good with? You think this isn't what OSHA was referring to in 1926.251? 


This sort of thinking goes on all day. Here it is with Mechanical contractors all over the country. They think they are doing good stuff by buying the $300 plastic bins that aren't crane rated. Why are they doing it? Because crane people aren't consistent and safety people aren't doing their jobs. OSHA. I've written a letter to the Washington Crane Department and they are focused on ensuring people know the yardage instead of the liters like people could pick a yard out of a materials line up. IE, they are wasting everyone's time with non-sense instead of enforcing their own rule which in Washington says ASME B30.20 explicitly. Yet they still allow plastic and wood bins to be lifted when ASME forbids this and requires steel. Hear that again. ASME B30.20 requires steel as the material used and welded construction. 
Washington State Code
This is the ASME B30.20 BTH Document requiring steel as the materials used. 

Plastic Totes used by Mechanical Contractors all over the country. Never crane rated. Not a legal lift. 

Here is the result of not being consistent. This man, not tied off even was walking in and out of this box to retrieve these windows from the OSB box. This is what happens when an industry looks away and we can't even enforce 54 year old laws. 

I've brought this issue up in polite manners over and over. On a construction safety forum on Linkedin. Safety people defended the OSB box and people walking in and out of it. Safety people. Degrees and certs. The next time I tried to bring up an issue there I was blocked. Safety people don't have the courage to discuss the issue. Where in the world does the addition of a strap change the rule? I'm yet to hear where that idea comes from. To date, it would seem that it's "because" is the answer. And that's where AI helps. 

This is meant to be a stick of butter on straps. How much load you putting in the center? Mind if I put your child on it? On a 100 degree day? We'll hang them for an hour. It's safe right? 

I am only having to make extreme arguments because people are refusing to see the reality of the situation. You don't know what wood is good for. You don't know when the plastic will become brittle. The ASME's are clear in defining deflection standards yet people in the field would act as if this isn't an issue and isn't known. Safety people do the same. I'm telling you to grab the ASME. Grab the BTH document that lays out the designs. Then consider how explicitly clear and broad 1926.251 is in pulling everything under it's umbrella. Look at the pictures of real issues and consider the AI illustrations. We need to do better. Even a company like Knaack who has been building boxes for us in construction for decades has begun to offer crane lifting attachments. Do you think this was just because, or in response to a problem? You look at the comments on their pages and serious boxes are rated at 100 lbs until you put the crane lifting attachments on. I have no knowledge of an issue. But this sort of thing and change doesn't happen in a vacuum. And that's the problem of our industry. An incident happens and everyone involved is motivated to not say what happened. And we all keep going in ignorance. We need not wait for the motivation of someone being killed to improve. 

Require a rating on what you are lifting and lift it as the manufacturer prescribes. If it doesn't have the tag or guidance, it's not rated for a lift. This is just the facts and the rules. This isn't my pushing change. This is the change from your grandfather's generation. Why are we still fighting against it instead of demanding safety? Whose side are you on if you want this to not be the standard? It's time for real and less polite conversation on this matter. Let's ensure everyone goes home today and not just stand back waiting for a public incident that no one of money and power can hide to be the motivation to do better in life.  















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