                Interview Reports- Operator Competency Programs
Table of Contents	
Interview #1- Concrete Construction Company	1
Interview #2- Crane Rental Company	5
Interview #3- Large National Crane Rental Company	13
Interview #4- U.S. Crane Manufacturer	18
Interview #5- U.S. Crane Manufacturer	22
Interview #6- Crane Rental Company	24
Interview #7- Canadian Certification Authority	32
Interview #8- Large American Construction Contractor	37
Interview #9- Utility (Power Lines) Workers Union	38
Interview #10- Equipment Operator Trainer- incl. Multi-Purpose Forklifts	45
Interview #11- Large American Construction Contractor Firm	47
Interview #12- High-Volume Home Builder	49
Interview #13- Major International Crane Manufacturer	52
Interview #14- Residential Home Builder	56
Interview #15- Large Construction Company	58
Interview #16- Medium to Large Home Builder	63
Interview #17- Safety Training Company	67
Interview #18- Large National Construction Firm	69
Interview #19- Regional Propane Tank Distributor	75
Interview #20- Equipment Operator Training Company	78
Interview #21- Large Construction/Crane Operator Training Company	80
Interview #22- Large Construction/Crane Operator Training Company	84
Interview #23- Sole Proprietor of Residential Home Building Company	86
Interview #24- Insurance Brokering and Underwriting Companies	89
Interview #25- Insurance Brokerage Company (1 or fewer cranes)	94
Interview #26- Midsized Framing Company (1 or fewer cranes)	97
Interview #27- Framer and Manufacturer/Supplier of Framing Materials	102
Interview #28- Association of Building Material Dealers	104

Interview #1- Concrete Construction Company

I. Introduction
On June 6, 2013, OSHA staff visited a concrete construction company at their corporate headquarters in the Mid-Atlantic. The company is a subcontractor that supplies, forms, pours, and finishes all reinforced concrete elements necessary for a total structural frame. They also provide and place all reinforcing steel and post tensioning as required. They provide all lay-out engineering and all hoisting required for their services.
The purpose of the visit was for OSHA to gather information regarding how the company determines whether an employee is qualified to operate a crane. The company also commented on whether operator certification needs to be by capacity. Finally, there was a discussion of their general operations related to cranes and operators. The first half of the discussion described two different paths to operator qualification:  1) a candidate with no operator experience, who is already an employee, and 2) hiring an operator who already has crane experience.  
II. Qualification for internal employee candidate with no operator experience for a tower crane
Determining whether an employee is qualified to operate a crane without observing the employee's work would be very difficult due to certain intangible elements of qualification. Operator certification is a good start, but does not mean an operator is proficient. Qualification is an evaluation based on experienced operators' judgment; here the supervisor of crane operators interviews candidates and makes all of the initial evaluations.
If an employee expresses interest in becoming a crane operator, they will put the employee in a tower crane on their own yard that is used for training. An experienced operator will instruct the employee on the operation of the tower crane for a day. Typically, the experienced operator (usually the cranes supervisor) can tell after a day whether an employee has some aptitude or skill to be a crane operator. If the operator is initially comfortable with the employee, he will put the employee in the crane and have the trainee hook up a material box, set up barrels in a yard, and drop chokers in a barrel over the next several weeks, as the work schedule permits. During this time, the operator will note how enthusiastic the employee is about being in the crane. If the employee is not enthusiastic or has a high level of stress or fear operating the crane, he will typically cease the training and let the employee know that he or she will not be an operator for them. Next, the operator will allow the employee to try some rigging tasks. When a trainee is comfortable operating the crane, he or she will operate a tower crane in some less demanding jobs. Initially, the trainee will also have an experienced operator in the cab. These jobs typically include cleaning up after the concrete work is finished or moving materials for finishing subcontractors and have a slower pace and fewer other employees on the job. The operator will continue to evaluate the trainee after each job and at each step of crane operation. The operator will observe the trainee's response to direction and signaling and observe how well he or she handles the crane. They observe new operators for their skills in moving the crane and load, how well they pay attention, how well they follow signals and cooperate with riggers and signalers. Crane operators are always under observation. Besides becoming better at operating the crane, part of the process of training is to increase the trainee's confidence. 
The trainee will generally take the crane operator certification test early in the training process. Operator certification indicates a basic level of proficiency. In addition, most general contractors now require operators to be certified.
Trainees work at lower heights, which may seem safer but can be more difficult to operate than higher tower cranes, which have longer load lines.  They use experienced operators for concrete work, as the pouring operation is critical, and they must move concrete loads quickly. They do not put trainees (or even qualified operators with only a few years' experience) into more demanding, stressful production situations.  
It is very difficult to take the practical operator certification test as a tower crane operator if your company does not have a crane used for training. For NCCCO, you have to provide a tower crane that meets all of their specifications, which is difficult if the crane is on an active worksite. Crane rental companies do many practical tests. Rental companies train their operators and typically send out operators who are qualified for the job. Certification does not mean qualified to the rental companies as well.
There is no formal rating system for evaluating a new operator's qualifications. Such a system does not exist because it would be impractical. A test or checklist cannot determine qualification, but certification is a good start and is beneficial. Certification does not equal qualification. Certification means you are an operator, but it does not mean you are qualified. It simply means you have a basic level of knowledge and skill.
It is possible to be qualified, but still new at your job. The more experience and skill you acquire, the tougher the jobs you are assigned. They give a new operator more work at increasing levels of difficulty as the new operator shows the necessary skill and drive. Operators are under constant observation, even after they are qualified to operate a crane. A qualified person is always on site to observe the operation of the crane or cranes. It is not necessary to be a crane operator to determine whether an operator is qualified for a job.
Generally, over time, operators will train on and operate larger cranes. Rental companies also train operators to operate larger cranes, as they acquire more skill and ability. 
In the end, whether an operator is qualified is a determination made by the company, not the certification body. To operate a tower crane, an employee must be certified and demonstrate the ability to operate the crane on a specific job to the superintendent. On their worksites, either you are a crane operator or you are not. There are no varying levels for training. If there are problems with any crane operator, the company pulls them down to discuss and evaluate performance. There are no small mistakes with cranes. General contractors, site superintendents, supervisors, and even riggers observe operators and provide feedback if there are problems. Other crane operators may also provide feedback on performance. 
III. Qualification for external employees with experience
The experienced operator approaching the company for a job as a crane operator must be certified. Most general contractors demand that operators be certified.  The supervisor of cranes will check the skill of the operator in the yard for an 8-hour day. After they are satisfied with the skill of the operator, they will check the experience and background of the operator. It is very unusual for an operator to lie about experience because he or she knows it will be obvious if the experience claimed does not match prior employer's records.   
The company generally uses newly hired experienced operators for less difficult jobs at first. On big jobs, with high production pressure for fast lifts, they generally use operators with more than 10 years of experience.
Qualification for Mobile Cranes: This is a very different type of crane. Potentially they are more dangerous, not standard, with more moving parts, and safety systems that the operator can bypass. An experienced operator stated that it is more important to train by capacity for mobile cranes than for tower cranes. As for as certification, it is impossible to have certification for every capacity, but a range might be feasible. Seventy percent of work is on 50-100 ton cranes. Some work at 100-250 tons, but over 250 tons is a highly specialized crane and requires special training. Type could be enough, if the employer is responsible for evaluating qualification. Other issues with capacity: crane configuration, bat wings, and counterweights. While certification is a starting point, type and capacity is not as important as the employer's determination whether an operator is qualified. An operator who usually operates larger cranes is not necessarily qualified to operate a smaller one, especially if the crane is an older friction crane. They will spend 1-6 months side by side with a new operator in these cranes. Load weight, or maximum load weight, is not the ultimate criterion for capacity. They use their own lattice boom cranes only to help erect their tower cranes, 200-ton models. Occasionally, they use mobile, lattice-boom cranes for a "flat job." Capacity needs some grouping by size, but you need qualification on all cranes. Generally, they move operators up by capacity, though. However, they always must determine if the operator is qualified. 
While an operator with experience may be hired, an operator's certification card is not enough to get them in the cab. The company must evaluate the operator's qualifications.  
Incident Reporting: The company keeps track of all incidents. Incidents are near misses, property damage, or injury. They investigate all incidents. They rarely have incidents, but occasionally when there is more than one crane at a work site, there may be contact between the boom of one crane and the load line of another. This leads to a meeting, discussion, and a drug test. Any contact between the cranes or their parts slows work because they must inspect the load line and structural components of both cranes before the crane is put in service. The company interviews all concerned parties and aims to find the root cause of the incident. They do log incidents in their database and review annually. They look at the trend data.
If there is an incident, the company automatically tests the operator for drug use. If the operator fails or refuses, the company terminates employment.
Drug Testing: Everyone is drug tested and has a physical at a set interval. There was discussion about what physicals reveal. Generally, as operators get older the issue that will arise is blood pressure. They said that there really is no enforcement or standards of disqualifying health issues in the industry. With blood pressure, the concern is suffering a blackout or loss of consciousness while in the cab. Some general contractors monitor the results of operators' physicals.
General Contractor Responsibility: This company likes that Subpart CC has more resulted in more site responsibility for general contractors, but when it comes to qualification, all the general contractor can really do is ask for certification. When a general contractor hires them, they simply provide the general contractor with a copy of the operator's certification. Whether an operator is qualified is the responsibility of the employer of the crane operator. There is no way to have a card that can tell if someone is able to operate a crane on a given site. General contractors are taking more responsibility at the worksite. Regarding the qualifications of crane operators -- very few general contractors can make any assessment.
Qualified Rigger:  OSHA's standards are workable in this area. The standard requires the employer to evaluate qualification with some guiding principles in the standard.
General Information: They constantly evaluate all operators. On the site, there is a representative of the general contractor, a superintendent, a supervisor in the field, and riggers.  They never let an operator in a crane without evaluation and observation. All operators are always under observation. Qualification is a daily issue.
They keep their operators performance on a database. The database lets the company know when an operator is due for a physical, certification renewal, etc.  As noted above, general contractors often monitor physicals.
Operators with more than 10 years of experience work on the biggest jobs. The operators' wages vary, but all the top operators are paid at the same wage. There are not rigid limits on the number of hours an operator can work. The days may be quite long, and the company may switch to two shifts to move production along (3 am to 12:00 (noon); and 12:00 to 10:00 pm).
They have meetings with all operators twice a year . At the work site, the operators have the final say on lifts. They can refuse to pick up a load. 
Third parties inspect crane assembly (tower cranes).  
They train crane mechanics, but there is no certification. They often send mechanics to the manufacturers for training.
They do lifts for subs, and this usually occurs after completion of the concrete work.
They have lift plans.  Their training in Job Hazard Analyses covers most lifts.
There was discussion of blind picks, where the operator picks the load or lowers it to a landing site out of his or her direct sight. They rely on cameras for these picks to watch the load and landing area. Operational aids help with the pick to some degree -- knowing the drop length and distance out the boom. Besides FM radios, they use cell phones and CB radios.  
This company has between 30 and 50 tower cranes and owns the majority of the cranes they use.
Interview #2- Crane Rental Company

I. Introduction/Background
OSHA staff met with an owner/manager and the safety and training director in a training facility of a crane rental company in the mid-Atlantic region.  

The business is family owned and operated, and relatively small, with about 20 hydraulic truck cranes between 15 and 110 tons.  The business started more than 50 years ago.  The firm had weathered the construction recession -- most of its business is for the construction industry -- and planned to hire two new operator apprentices in the near future.  

This company only provides hydraulic truck crane rentals with an operator.  It does not rent its cranes as bare rentals.  Renting cranes alone results in getting "junk back."  People treat rental cranes like rental cars.  Typically, each of their operator/drivers remains assigned to the same, specific piece of equipment.  This encourages the operator both to be very familiar with its characteristics and to be responsible in inspecting and maintaining the truck crane.  Even for identical models of the same crane, every one of them is different and has a different feel to it.  This results in safer operation of the crane.  "It takes you a little while to get used to a machine--here everyone feels proficient."

The company once also rented larger all-terrain cranes, but ended that business for a variety of reasons.  One of the principal reasons was the ability to transport smaller cranes over roads more easily.  Truck cranes can travel on public roads at all hours, but the larger all-terrain cranes are limited to daylight hours or less in some states; typical hours in some states can be from 9:00 am to 3:00 pm.  

A large percentage of the rental activity supports framing and carpentry work.  Prior to the recession, approximately 50 percent of the company's activity was in housing construction.  By 2008, the housing construction sector had disappeared and the company survived by cutting back hours from 40 per week guaranteed to 30 per week guaranteed and finding work in road and highway construction and commercial work. They have subsequently been able to bring their employee hours back up to 35 hours per week guaranteed, with some operators doing multiple projects in a day.  Today most of their rental activity is: trusses, carpentry, steel erection, mechanical contractor (rooftop AC or heating units), and underground concrete structures.  

They qualify crane operators along two paths: an apprenticeship program for operators with little or no crane experience, and verifying the qualifications of experienced operators.

II. Apprenticeship Training Program for New Operators

The company inaugurated a new written safety program in 2011.  The program for a brand new operator can take 1 to 3 years.  The company infrequently takes on new apprentices (maybe once every year), but plans to hire 2 this year.  The process to break someone in can take from six months to a year, and to get the training to become fully qualified can take up to three years.  The company more frequently hires people with prior qualifications and experience.

Prescreening: When looking to hire a new truck crane driver/apprentice crane operator, they look for someone who already has a CDL and trucking experience--and who has some other association to construction or crane work in their history, such as carpentry, steel erection, and/or something that demonstrates that person's interest in cranes. For example, the right hire might have worked right alongside with the cranes/etc. 

When the owner/manager is interviews a job applicant, he will show them the crane yard, and may set up a small crane in the yard and let them try the controls, in order to see if they respond in a positive way.  If the candidate demonstrates little aptitude--that shows that they have no business operating a crane--the candidate is informed of this and let go. During this initial introduction, the owner/manager is sitting next to the candidate during this short practical test, both for safety reasons and to better observe the candidate's performance. 

Training: If a candidate passes the initial test/interview, and his or her background and references check out, he or she would be accepted as a trainee.  The program is individualized: "a trainee will start with what they come to us with, then there are essentially 3 stages; you can go through as quickly as you are able to show competence."

Three-stage Training Program: The operator in training will spend their first 3 to12 months on the job as a driver/apprentice.  Every day will be on the job training (OJT) as an apprentice--either driving a support truck and helping with set up, etc. or driving a support truck that carries mechanical contractor's equipment.  The new employee will learn to help assemble the crane, and help with the crane on site.  The apprentice is already a driver, so unloading the equipment off the truck for example is usually not completely unfamiliar. Stage1 can last between 2 months and1 year, depending on how often they can get seat time in the yard, how well they take to it, and how quickly they learn.

They thought that OSHA identification of work (in the crane standard) that trainees should not do was very good.

The first 3 months are probationary. After this time, a determination is made on whether the new candidate is going to "get it" (or, if they have the aptitude). If they are not at the appropriate level, they will be screened out and further training as a crane operator ceases.  

Stage 1: During Stage 1, the operator in training is under direct supervision at all times.  During this stage, the apprentice gains in experience going out in the field and working with an experienced crane operator.

Stage 2: The apprentice should be able to assemble the crane by themselves, and drive a crane under the direct supervision of a trainer. This is usually done in a"2-seater," a boom truck with 2 seats. The apprentice is also assigned to an experienced operator, and they will accompany that operator out to different jobs and assist the operator. The apprentice still may not operate a crane on any job site. During much of the early training, the owner/manager focuses training on "protecting the ball." An apprentice must be able to control the headache ball or load before moving on to stage 3  -  and before being able to perform jobs on the worksite.  According to the owner/manager, anyone can learn to set a crane up and tear it down, etc. The measure of whether an apprentice is going to be a good crane operator depends on how well they can control or maneuver the headache ball. During training sessions, a face may be painted on the ball, for example, to encourage careful movement of the ball as if there is a person in a boatswain's chair.

Stage 3: The apprentice must now also know traffic control, and he or she will need to know how to use the crane in the yard, including assembly/disassembly. Apprentices at this stage can operate a crane on the jobsite under direct supervision and in limited circumstances, and the apprentice will demonstrate the ability to promptly respond to signals.  Before operating a crane on the jobsite, the apprentice will need to fully know voice signals, inspection procedures, and how to avoid hazards. The apprentice continues under the supervision of the experienced operator until that person is ready to be tested by the owner/operator and assigned his/her own equipment.

Meanwhile, during this process, the individual is also completing the formal written training requirements, including completing the CCO training on site (all signal, rigging and op cert is done in-house  -  the safety and training director is certified in NCCCO training, as is owner/operator). This can take place at different times, during inclement weather, usually when they aren't going out on jobs. The first priority is to get the apprentice through the rigging course and to issue a rigger card, then to issue the signalperson certification, and finally the operator certification class and written test. A crane operator doesn't necessarily need to be a rigger to run a truck crane, but certifying their operators in rigging is one of their "one step above" safety requirements. Knowledge of rigging also helps the operator, as when an operator doesn't have a job to go out to, they can accompany other operators and perform rigging tasks.  

Once apprentices have passed the CCO written exam, they take the practical test.  Apprentices can take the CCO truck crane practical test on site; however, if they would like to get certification for other equipment, they must go off site for those practical tests. With CCO, the practical test can be completed up to a year after the written test.  

Apprentices are learning at a pace that depends on (1) actual one-on-one teaching time, and (2) the apprentice's ability to absorb and demonstrate new techniques and knowledge.  Every day the apprentice is getting OJT.  

Somewhere between one and 3 years on the job, after formal training has been completed, the apprentice will be ready to graduate to a new operator.  The experienced operator that an apprentice is training under will let the owner/manager know that the apprentice "has got it," and the owner/manager will go out with the apprentice on several trips to judge whether that person is actually ready to go out alone.

Once the apprentice becomes a fully qualified operator, they will be assigned to their crane when one becomes available.  At this company, all operators are assigned to a single machine and are responsible for all of the inspections, cleaning, and maintenance of this machine. The operator is given full responsibility for that one crane. The owner/manager says that this increases safety, as each operator is fully familiar with the feel and operation of his own crane. 

Apprentice program is new:	 This formalized program is relatively new, and no apprentice has been through the formalized training program.  It includes sign-off sheets for trainers to sign off on skills learned. There is no official record of seat time/hours, however.  

Evaluating Employees after they get through the program: New employees are held accountable by continual observation, assessment, and evaluation:
(1) Random site safety inspections are conducted by owner/manager and safety and training director
(2) SAFE program- includes rewards and discipline
(3) Customer feedback  -  The company will react to compliments given by customers as well as the rare complaint, and they often send new operators to jobsites where we know they will get honest feedback.  (The company has tried general customer satisfaction surveys, but did not find them very helpful, as reviewers only gave positive feedback. In direct contact with customers, they occasionally get positive feedback, but more often get negative remarks. People do not usually volunteer, "Your operator did well"; negative feedback is more frequent, despite the fact that the vast majority of customers are satisfied with their experience.

The company also has a disciplinary program: When an accident occurs, operators are brought before a board of 3 people (including the owner/manager and the safety and training director).The board then determines what happened, and how the incident and operator will be managed. 

The company conducts toolbox talks once a week; these meetings cover lessons learned and how to avoid hazards.

They don't use the term journeyman or other similar term, they just call their employees operators, and that would describe a newly qualified operator as well as a person with 40 years of experience. The company knows what types of jobs they would and would not assign to each operator based on their experience and individual strengths and weaknesses.

Once employees come to the end of their careers and near retirement age, they might decide that they don't need to have the responsibility of operating a large machine and they may choose to operate a smaller crane. The company has employed 70-75 year old operators, but everyone has different skills, health, etc. as they age. Older crane operators get special attention from managers, and they are watched to ensure that their skills remain sharp and that they continue to be safe operators. 

Role of Health/Medical Physicals: Medicals are required by CDL for truck cranes every 2 years, also there is a random drug testing component. The owner/manager expressed some concerns that the physical does not include blood lab analysis that might pick up some heart or other conditions.   
	
III. Ensuring the Qualifications of Experienced New Hires 

When an applicant calls in response to an advertisement, the owner/manager will ask questions about what types of cranes the applicant has been running and the owner/manager will take notes and determine what appears to be true, versus what might be an exaggeration. For example, maybe they say that they ran a120-ton crane regularly, when they maybe only pulled the leavers once or twice.

The owner/manager will then ask detailed questions about where and how long the applicant has worked different jobs, and what types of jobs and scenarios. To work for this company, an operator must be capable of going out and doing many different types of jobs.  Some crane operators are not forced to perform under such different and varying conditions. If they are working on a 300-ton crane, but they are running only 100 feet of boom, and they're lifting the same object from point A to point B every day, in the owner/manager's opinion, they are not a fully qualified 300-ton crane operator, even if that particular job was done with a 300-ton crane.  Boom length (capacity) matters.

The applicant will talk to the owner/manager about what they have already done, and what they did with different sized equipment. If in that conversation, the owner/manager catches something that makes him want to consider the applicant further, then the owner/manager will "get their papers and read about them" to get a better sense of what they've really done.  

Documentation required of applicants: Primarily resume, the candidate will also have to download the company application from the website and fill it out. This application contains questions that will convey information that the owner/manager focuses on.  The website application will also generally include a sheet of certifications.

After the application and resume have been submitted, if the owner/manager is still interested, the applicant will visit.  At that point, the applicant and the owner/manager have likely talked enough for the owner/manager to show the applicant what types of cranes and facilities the company has.  During this walk around, the owner/manager is determining whether the applicant knows what things are and paying close attention to the candidate's actions and remarks. If the applicant is representing themselves as the Cadillac of crane operators, then it is reasonable toask them to inspect a piece of equipment "as though they were going to drive to California." He then asks the applicant to pull the crane into the parking lot and set it up for operation.

Then the owner/manager watches how the applicant responds and performs. Does the candidate do a full inspection and do they set the crane up properly? If the candidate did the inspection and set up correctly enough for the owner/manager to allow the applicant to continue, then the owner/manager watches how the candidate runs the crane. That is the interview.  After this step, the owner/manager will check on candidate references and work experience.

Once hired, experienced new hires still will be evaluated closely before allowed to operate a truck crane independently. Many new hires may not have been in rental work in the difficult traffic of an urban area. The new hire will ride with an experienced operator for a week to see how things are done with their company. Even if that experienced operator only runs a 30-toncrane and the new hire may think he knows more, the experienced operator knows how things are done at this company--for example, how the ticket gets signed, how to talk to customers, etc. 

Even if the new hire claims he already has run a 100-ton more than just main boom, the owner/manager will put the new hire on a 70-ton crane in the yard, to show the new hire how that crane has a little bit of a different feel. It doesn't matter if he has run other 70-ton truck cranes before--he has to learn to operate this one.  If the company has the luxury of having the former operator for that piece of equipment available, the most recent employee on that machine works with the new hire to get them familiar with its idiosyncrasies, and will work with the new hire for 2-3 days to one or two weeks.

Once the new hire is allowed to operate a truck crane on his own, the process is the same for all employee operators. The safety and training director will perform spot checks by going out and about, doing ride-by checks. They will also contact customers for feedback on the new hire's performance out on their jobsite, especially with long-time customers who are more likely to give honest feedback.

Sometimes new hires have to be backed off of certain pieces of equipment, and are put into status that is more like an apprentice. They get more review when they don't have the skills. If they are started off on a 100-ton crane, but seem to be struggling with that, then they might be stepped down to a 30-ton one. Learning that someone oversold himself during the hiring process often means that the employee gets rolled back down. 

Employee Wage Structure: Wages vary by size and capacity of crane. As operators become more experienced and proficient, and a larger-capacity crane operator retires, or the company buys a new crane, etc., people will move up internally.

IV. Other Topics

Insurance: General contractors require proof of insurance. Having all of your operators get operator certification lowers rates. Today, insurance companies may specifically ask if operators are certified by CCO. The owner/manager recently reduced his company's insurance rates by 25%by not working on trees, usually after storms.

Experience ratings and accidents and incidents?  For the past several years, their company has experienced 0 loss runs; their rates do decrease, but the lowest price is still tied to the risk of the work being done by the industry as a whole.  

Is rate affected by size of company?  The owner/manager did not think so. The company has managed to walk through 3 years with 0 losses. The 0 loss rate only helps in that they're able to buy insurance at the lowest rate that the insurance companies offer. That doesn't mean the rates are low, or that they never increase; their rates are lower in relation to the other companies. Unfortunately, all the other losses out there that are unrelated to their company may increase the lowest rate. With years of 0 losses, they have the lowest possible rates, but that lowest possible rate has still gone up.

Operating engineers/etc.: IUOE has a very long apprenticeship programs.  The Local has a 5- year program. Sometimes a member will come to work for them and become qualified; once qualified, they may return to union work as a qualified operator without going through the full, 5-year apprenticeship. The qualification process at a private company is shorter.  

Supports Capacity and Boom length based certification: Maybe capacity bands are needed--like 0-100 ton, and 0-150 feet of boom and 100-200 ton 150-300 feet of boom, and 200-400 ton 200-400 feet of boom, and by jibs versus luffing booms. It might be possible to have tonnage and some boom length cards and then even some luffing cards, including 500 ton and larger.  Maybe there should be the option to have a "Master of All" certification as well. 

Can an operator drop down in size and be safe? In the owner/manager's opinion, not necessarily, especially if going to down to an old clutch and band machine. Every machine is different, and knowing how to operate one type of crane is not necessarily going to make you good at operating a different type.

Are customers the people that you hire aware of CCO and operator certification requirements -- or OSHA requirements?

They have some customers who are completely unfamiliar with current OSHA standards; most of these are residential homeowners who rent cranes. They don't even know what questions to ask. Residential homeowners comprise approximately 25% of the company's business. The top 25% are the other side--general contractors or contractors with good safety programs who adopted this a while back. They require documentation before even coming to site. Many have their own crane program/own prequalification paperwork, including number of hours each man has on the specific type of machine.  This business is on the board with NCCCO, and sees the certification as an important part of the process.  

Some employers don't know signals, standards, proper rigging etc. When their crane operator goes out alone, he is at the mercy of the people there. This is one of the reasons they require all driver/operators to become certified riggers and signal persons--at least they are aware when others on the jobsite are doing the work incorrectly, and they can stop and correct mistakes. 

Some crane operators can be functionally illiterate. In the 1950s-70s, many people in construction did not go past 5[th] grade in terms of education; they entered the working world young and got into construction.  These folks are great at operating cranes, but cannot read/write/do arithmetic.

In 1996-98, the owner/manager encountered some people who were going to have to pass an exam as veteran crane operators, and worked at helping them pass the test. Even so, once they got out in the world, they realized it was not required some places. 

Something is broken- in this case it was the craning world. There were a whole lot of good people in this industry  -  this company already had a commitment to safety  - good track record, now fairly heavily regulated to do so- any time we tried to push a law and the industry did need it, it creates a snowball. Impending snowball must be necessary, but it is a painful process. But there were too many accidents. Individual operators are pushed or allowed to jump up in due to convenience.  For example, Johnny doesn't come to work one day, so Jack has to come to work and run the crane. Jack doesn't have a whole lot of experience on the crane, but he was the one who ran it the most with Johnny. This is where the most accidents occur.


Discussion of potential for cameras: They did not like this idea of putting camera on the rear of their trucks. They recently installed GPS's on all of their truck cranes, and they can see where employees are located, how fast they are driving, when the crane engine starts, whether they are idling too long, etc. 

Crane operators are "prima donnas"--they have confidence in their abilities.

In the 1990s there were far too many accidents.  Typically, due to inexperienced operators, pushed into the seat or allowed in.  Certification was casual, in an emergency employers would just grab the best employee available as an operator. On owner-operators: most are safe.

Interview #3- Large National Crane Rental Company

I. Introduction and Background

OSHA staff met with the CEO, the Head of Safety and a field manager from a large, national crane rental company ("the company"). The company rents cranes both with and without operators (called "bare rentals").

The company owns all of the cranes that it rents. It provides the operators for approximately 60-70% of its rentals; the remaining rentals are bare rentals.

II. Types of Cranes

The company owns and rents crawlers (lattice boom cranes), tower cranes, all-terrain cranes, hydraulic truck cranes, and rough terrain cranes. Hydraulic truck cranes are all of less than 100 tons of lifting capacity.

III. Bare Rentals

In a bare rental, a crane company only provides the crane and the customer provides the operator and maintenance. All that delivered by the renter to the company is proof of insurance with no information on the prospective operator of the rented crane. Repeat customers give assurance that they use certified operators. Many bare rental customers use union members as operators. Seventy percent of the company's incidents are from bare rental customers. All damage to the equipment done by the renter is billed back to the renter by the company. 

IV. Operators

Tower Cranes

Tower crane operators are completely separate group from mobile and lattice boom crane (crawlers) operators.

Crawler Cranes

Crawler operators do not usually operate different machines. The company selects all operators of its cranes based on experience. 

All-Terrain Cranes

The all-terrain cranes are the most complicated to operate. The most difficult part of operating an all-terrain crane is driving the crane on roadways. 

Lower-end Boom Trucks

There is a high rate of reportable incidents on boom trucks because every operator thinks he can run a boom truck. The company is reducing its fleet of boom trucks due to such liability issues. Of the 30 boom trucks that the company owns, few are rented and the company is phasing out such cranes, and thus it no longer trains new operators on those machines.

V. Operator Qualifications and Training

Where Operators are Found

There are two principal modes -- candidate operators who start from scratch and operators who already have experience. All Hired operators are members of the International Union of Operating Engineers (IUOE). Eighty percent of the company's operators are retained operators (i.e., hired by the company on a long-term basis). Twenty percent are "call-outs" from the local union hall. The call-outs are usually retained for short-term jobs.

The Company's Qualification Program

Apprentices

The company's safety personnel conducts a new hire orientation covering policies, procedures, and responsibilities. An apprentice starts as an oiler, which this job category maintains the crane on the job site (i.e., fueling, cleaning, lubricating, and assisting as directed by an experienced operator). An apprentice gains experience through observation, mentoring, on-the-job-training, and formal and informal assessments by the operator. Restrictive measures are implemented to ensure that an apprentice operates in compliance with OSHA regulations.

Oilers (Candidate Operators)

Oilers are "operators in training" and are in the apprenticeship program at the union hall. Oilers receive close monitoring by the primary operator during the performance of specified crane tasks. The oiler must be supervised by an experienced crane operator while at the controls of a crane. The oiler can also be a "certified operator" while undergoing training on a larger, more sophisticated crane.

Operators

The crane owner maintains the right of refusal for any new hires out of the union hall. An observation/evaluation period is implemented in the crane owner's local branch. The operator must have an operator certification from a recognized training institution. The crane owner evaluates the operator's knowledge, depth perception, drift avoidance, boom deflection, etc. to establish his or her experience level. As more experience is gained, the operators graduate to larger cranes. This advancement is based on close monitoring by the company's dispatch operations and safety division.

Role of the Union

The union provides initial safety training (signal person training, rigging, OSHA 10 hour training, etc.). Some crane familiarization training is provided by the union, but due to the union's limited resources, it cannot truly qualify operators. In becoming certified, the operator takes a test and gains some familiarity with load charts, but going to the next step is the responsibility of the crane owners. The union is a good screening source for crane operators, but does not have the resources or crane equipment to complete the training of a crane operator. The company has observed that crane operators are usually only a small part of union hall membership.  The main occupation of union members is as "dirt equipment" operators. There is no "weeding out" process within the union system.

Monitoring and Evaluation of Trained Operators/Continuing Education Training

The company conducts continuous monitoring of its crane operators. There is a global positioning system installed in all equipment to monitor speed compliance. The company has a strict accident/incident reporting requirement with no exceptions. The company has a site audit program. The company tracks crane abuse and neglect of maintenance. A lack of compliance with company protocols results in the operator being sent back to the union hall. Training is provided , and all training results are tracked and maintained in a company-managed database. Weekly, monthly, and quarterly training sessions are conducted.

Jobsite Protocols

Rigging is the process of connecting the load to the crane. Rigging is a multifaceted operation, is usually performed by contractors and subcontractor, and is not the responsibility of the crane owner or the crane operators (outside of rigging their crane components during assembly disassembly of the cranes). Having "qualified riggers" is not an issue; instead, lack of engineering is the principal problem. Riggers must be given the accurate information about the load prior to performing the lift, such as:

   1. Information about proper pick points on the load
   2. The center of gravity of the load
   3. Accurate load weight

Job Planning

The company requires a pre-lift meeting with all employees involved in the crane activity. A job data sheet is created that covers the details of the job for the operator, and is available prior to getting onsite. Any changes observed or that come from the pre-lift meeting will prompt a revision of the job data sheet. Assembly/Disassembly processes are set forth in a job safety analysis (JSA) program and in the crane operator's manual, which are reviewed by the crew.

VI. Lessons Learned by the Company about Operators in the Crane Business

Qualification of crane operators should be the responsibility of the employer/crane operator. This opinion is based on property and tort law. The company is worried about everyone who works around the operator, including non-employees. Riggers and bystanders can all get hurt and the responsibility for the crane operation should be placed on the employer of the crane operator.

The company's advice to customers who don't have long-term operators  -  Don't do bare rentals.  Unskilled operators break the bare rental cranes. It is better to rent from the company or similar companies, and let the experienced company operators control the crane (the company tries to discuss this matter with clients and asks if the client is sure it knows what it is doing when it does a bare rental).

There are three essential skills needed in the crane business, the operator needs to know how to: 

   1. get the crane down the highway to and from the jobsite
   2. build and dismantle the crane, and
   3. operate the crane.

A crane renter cannot really merge all three requirements together  -  and all three must be mastered to be a good operator. Even when you have the transportation and assembly right, an operator still needs to have an eye for the distance the crane arm (boom) travels. With all of the activities that need to be done correctly, there is no doubt that you have to hold the employer of the operator responsible for the operator's qualification. 

VII. Crane Rulemaking

The company thought that the OSHA's 2010 crane requirements were largely good and the crane safety culture has been improving. Contractors inform the company that insurance companies are telling the contractors to get rid of cranes for general contractors, and are recommending that they sub the crane work to the company. States and localities are merging their crane regulations because if they are not consistent, it could present problems, especially regarding different attitudes towards safety. One change in recent years is the relentless drug testing of crane operators, which the company supports. In regards to drug testing now, many people can no longer work for the company. Drug testing has been a big help in reducing incidents and accidents. It eliminated 70% of incidents and accidents. When insurers raised deductibles, it resulted in employers addressing and identifying the causes of accidents. Refineries began the move to drug testing for their crane operators.

The effect of OSHA's crane standard on general contractors was very good. They are much more responsible about ground conditions now. Another effect of OSHA's crane standard is that some employers are getting out of the crane aspects of their businesses. A refinery, for example, may have 400 employees, but only 10 crane operators. They recognize they really don't have any expertise to support crane operation training.

VIII. Insurance

The insurance industry does not publish crane loss information for crane companies. Besides having high deductibles on its general liability insurance, the company also self-insures considerably on works compensation. In 2001, insurance premiums increased greatly for crane renters. Some insurers stopped covering cranes. The $ 10, 000 deductible disappeared. There were issues with general contractors and insurers essentially were requiring subcontractors to insure the general contractors' risks. Texas and California have changed their crane regulations. Before this legislation, there was an illusion of a safety culture.

IX. Losing Trained Employees to Other Companies

Highly skilled operators are a valuable commodity to other crane companies and customers that have their own cranes. Sometimes it is a problem that the company has trained an operator, incurred the substantial expense for such training, and then had the operator go to another crane company that may not have the company's training and safety programs. However, an employee that departs is not as valuable to the company after 5 years of working elsewhere because of the static situation they usually have as an operator at those companies.
Interview #4- U.S. Crane Manufacturer

I. Background
OSHA staff met with a U.S. manufacturer of cranes. The company has a number of crane operators who test cranes off the production line. Every crane is tested before it is sold or delivered to a customer. All of the operators are certified via NCCCO. Even more of the production staff at the site are also certified.    
The company provides training or licensing to users of its equipment in some European markets.
II. Operator Qualification
There are three components of operator qualification:  knowledge, training, and experience or repetition. The company can provide the knowledge in the classroom and hands-on training on equipment, which can be tested to ensure that a candidate operator has absorbed the knowledge and crane control functions. The last part, experience, occurs over time at job sites, for their own operators as well as operators/customers of their equipment.
A crane operator said that the classroom training he received at the certification course was good, but such training was not on the job training, which was more important. He stated that he is not an operator using a crane "out in the field," a task at which he felt he would not be proficient. He also noted that they often had more than one operator performing tests on cranes, which may not be the case out in the field.  
Supervisors identify the most capable operators and may assign work based on the individual abilities of operators. The operator started his career as a rigger and progressed upward to a crane operator. He was a rigger for 7 years.  His progression was a little slower than normal because he wanted to stay on a particular shift.  Progression could have been quicker if he jumped to different shifts when opportunities arose.  He stated, "When your number comes up, you get a crack at the seat." On at least one occasion, an operator has been "weeded out" from being a crane operator due to poor performance.  
Their own operators are recruited from within manufacturing or other operations.  They will typically be involved in testing finished cranes before they are put in a cab.  New operators start out as riggers or support crane testing for the smaller cranes, boom trucks and industrials, and over time as opportunities arise graduate to working and operating larger cranes. They believe that the cross training as a rigger is helpful so everyone knows what to do during a lifting operation.  Generally, at their facility as well as at customers', if you want to find the most experienced operator, he is on the larger cranes.  Most experienced operators run the larger cranes because the crane is more complex and the operator needs: 
   * more knowledge of various configurations of cranes; 
   * to be able to read complicated load charts (for example, some all-terrain cranes have load charts that are thousands of pages long); and
   * more skill to go from one operating system to another.

For their own employees they have a matrix (kept as a spreadsheet database) of staff who may be called out to customers (based on size and complexity) to help in some way. They categorize their staff as apprentices, field engineers, erectors, ...and inspectors. In order to qualify and be sent to work on customers' cranes, the knowledge, training, and experience (i.e., number of site ops) is checked from  the database (the "competency database" is only 2 years old) and must meet their assessment of the individual's experience and abilities. For example, tests of knowledge are scored and kept. When staff are sent out (inexperienced staff are never sent alone), field service managers will record job site performance into the database. Supervisors are also responsible for entering records of employees' experience. 
III. Operator Certification
Their understanding of OSHA's standard is that only employers will be able to qualify crane operators. When the final construction crane standard was published, with only a requirement for operator certification after November, 2014, they identified the lack of employer qualification as a problem. They stated that you cannot simply look at a card or a piece of paper to determine qualifications; it is a foundation, but does not get close to qualification. 
They questioned the use of certification and noted examples from California when that states' regulation began. They mentioned as an example a welder who was certified over the weekend and put in a tower crane on Monday at a construction site. They believed that most of the cranes that are used for certification programs today are probably out of date simply due to the wide variety of crane configurations and control systems that cannot be captured during the practical testing of the operators. The testing organizations typically buy older and smaller models of cranes to use for practical testing of operator candidates. Certification programs were more appropriate when most manufacturers still used basic level control systems.
To have an effective competency program, the employer must also provide training that includes information that is specific to the crane the operator will run at the site. That training must be closely followed by an assessment of the operator's proficiency at running simpler cranes to do relatively simple hoisting jobs.
The company considers the training that it performs in some markets to certify or license crane operators to be far better than the operator certification requirements in the OSHA crane standard. In their training, operators must prove their competence, and much more is covered, such as assembly/disassembly operations.  
Crane certification as a concept is good, but it is out of date. When crane controls were just a bank of levers to pull, instruction and familiarizing was an easy training exercise, but that applies less and less today. The controls of different manufacturers on the same type of equipment are completely different. Can their own operators move between cranes of different manufacturers? No. Controls are unique to the manufacturer. A license or certification does not mean you can jump between different manufacturers' equipment. Control systems are making their way down to boom trucks. Electronic joysticks or remotes can be found on the smallest equipment. Electronics continues to become relatively less and less expensive. An example was mentioned of an operator familiar with Rough Terrain cranes tipping over a Boom Truck due to a simple error in identifying controls.  
As of now, certification is general to all products.  An operator must be qualified and familiar with the crane he or she is going to operate that day. The employer has to ensure that daily. Only the employer has influence or control over the operator's actions.
Even with a prerequisite number of hours of crane - related experience, the certification of operators is not enough. They referenced OSHA's Powered Industrial Truck Training standard as a good baseline. Operators must be evaluated on the job. You can track experience, the type of functions being performed, but for construction companies, time is money, and putting multiple employees on a crane--such as supervisors, oilers, and riggers--is expensive.  
IV. Training and Service for Customers
The company provides training, if requested, to customers who buy new cranes.  This training is "technical."  It covers crane assembly/ disassembly, set up, how control systems work, troubleshooting and diagnostics and may also cover mechanical and inspection issues.  They provide assistance on troubleshooting, which helps customers respond to problems or warning messages from the control system, and how to identify and isolate the source of problems in the various components of the system (i.e., hydraulic and electrical systems).  They equated this to a factory certified mechanic for a car.  Most of the focus is on the crane control system, because new cranes usually have computer-involved control systems.  Technical training usually occurs over one week, but  may last for two weeks or so and may consist of repeated tasks of setting-up and breaking down the crane. Each employer has different needs.  They do not train customers on lifts or normal production function of cranes In the U.S., this training also does not ensure the operator's competence to operate the crane to do hoisting jobs at a worksite.
In some markets they train or license operators (due to a requirement in those jurisdictions) who use their equipment.  The training may last up to several weeks for complex, large cranes. Re-certification is typically every 3 years. Operators can usually operate a range of capacities of the particular type of equipment for which they are licensed. Some markets have several levels of certification.  
The manufacturer can serve as tech support for the life of a crane, not just when the crane is new. When there was a shortage in the demand for crane jobs, employers often lost their experienced crane operators, especially those who could do A/D work. This company is often contracted to be the A/D director at worksites and to provide training for A/D crews. A/D Inspectors are the most experienced and often become A/D supervisors. 
V. Type and Capacity Issues
Capacity, as represented by maximum lift weight, is not necessarily the critical issue for operators working on different cranes. For example, an operator who is competent on a very large hydraulic crane would not know how to operate a conventional (friction) crane safely.
Capacity is not proportional to the complexity of machines. You can have a smaller capacity machine that is more complex. Capacity as maximum lifting weight is not the issue; it is crane configuration. 
Different levels of certification should not be based just on maximum crane capacity alone.  Crane configurations and control systems must also be taken into consideration. For example, an operator that is experienced in running one make of crane will not be able to just jump into another make of the same type of crane (comparable capacity) and operate that crane safely simply because the operating controls may be different. Pushing the wrong button or pulling the wrong lever in real time during a lift can be catastrophic. Familiarization with the crane to be operated is essential to performing the job safely.
Telematics:  New, larger cranes often include software that may report the location of the crane, crane operations, and any problems or hardware malfunctions. This is an issue within the crane industry as some do not want this equipment on the crane or automatic reporting.  
Computers in newer cranes can monitor hours of operation, operating parameters like boom angles, hydraulic pressures, or relay warnings related to overloading, two-blocking, , etc. The system can also log when the LMI system has been by-passed, or turned off, as well. The company intends to use such a system in the future to coordinate servicing/inspection programs, to troubleshoot services for its customers, and to obtain data about where and how their cranes are being used around the world (i.e., asset management). However, some crane users are concerned that this information can be used to invalidate warranties of other purposes such as support for litigation should there be a crane incident.
Owner/operators:  Mostly work with boom trucks. Most of the time they are good operators; however, sometimes operators trained by a large company will buy a boom truck and go into business for themselves and they may or may not be qualified. They mentioned an example of an owner-operator who had an accident recently due to lack of maintenance.
Interview #5- U.S. Crane Manufacturer

I. Background
OSHA staff met with the Director of Product & Corporate Safety at a U.S. manufacturer of cranes. The manufacturer sells boom truck cranes with capacities ranging from 18 to 38 tons. The booms on these cranes range from 70 to 127 ft. In addition to sales, the manufacturer offers bare rentals, primarily for customers with whom it has an established business relationship. The manufacturer also provides testing locations and proctors for NCCCO and CIC certification tests. The manufacturer has a long relationship with NCCCO.
II. Operator Qualification
Maintenance personnel employed by the manufacturer undergo an in-house developed program for training and qualification. This is a limited one day program designed for those employees who will only perform tasks necessary for test lifts. Some of these personnel are certified operators, but not all. These employees are not required to know how to read load charts or how to perform the full range of crane operations. Their role is primarily quality control. This program is offered for the manufacturer's customers in jurisdictions that do not require certification.
The manufacturer's operators who perform more complex operations are all certified. These operators are involved in proving the functionality of new products, and must perform the full range of tasks the equipment is capable of. 
The manufacturer offers operator training and certification programs through NCCO and CIC. Each instructor for this program costs about $2,000 per day, so the costs involved depend on how many operators are trained at once, typically 15. The crane operator training is generally a six day program. It consists of 4 days of instruction, one day of practice, followed by a final day for the practical exam. 
III. Training and Service for Customers.  
For customers who buy equipment, the company offers assistance with familiarization and observation. The company will check to ensure that the operator knows certain things such as the location of manuals and specific crane features, functions, and safety devices. The company also provides a checklist for the operator's employer to facilitate an ongoing evaluation after the company's involvement ends. The manufacturer believes that kind of equipment specific familiarization followed by extended observation is sufficient to qualify a new operator to use a specific piece of equipment. 
IV. Type, Capacity, and Other Issues

   1. Qualification on a smaller crane does not necessarily mean qualification on a larger one. Larger cranes have additional features and more complex load charts.
   2. Most accidents happen because of improper setup, which is not assessed in the practical portion of certification programs. It is in the written portion only.
   3. A lack of proper inspections causes many accidents as well.
   4. The manufacturer also does yearly inspections for many customers. However, the manufacturer does not meet impartiality requirements in some jurisdictions for these inspections. 
   5. Certification bodies are in the best position to determine what range of equipment capacity their certification is for.
   6. The manufacturer offers training for rental customers. The customer may decline this training, but must do so in writing.
   7. One cause of many accidents is incorrectly judging the weight on trees. 
   8. The manufacturer does not use distributor companies. These distributor companies often provide training when they sell a crane.
   

Interview #6- Crane Rental Company

OSHA staff met with the safety manager and president of a crane rental company to discuss crane operator qualification. All of their crane operators are from union locals (operating engineers). The company has 6 safety guys in the field and 4 more who train or do company-wide safety activities.
I. Operator Certification
They have relied on NCCCO for certifying their operators since the mid-1990s. The reasons for working with NCCCO are that they have been around longest, are a nonprofit, and the industry supports them. In the mid-1990s the company began certifying their operators for a variety of reasons. Certification provides good info on types and sizes of machines, i.e. small, large, and hydraulic, different classifications, and how to read a load chart (including reading the footnote interpretations).
A certification is like a driver's license. It does not mean that an operator walks in and runs a crane for them. However, once certified, an apprentice operator will have a basic understanding of the fundamentals. Most important is the education operators receive on reading and understanding load charts- a key element of crane safe operation. 
It is a comfort on their end that a certified operator knows how to read load chart and other crane basics. But an operator cannot run any machine he or she wants just by virtue of a certification card. The company will test the operator and put a seasoned operator on a machine with a new candidate operator until they earn the company's confidence. Millions of dollars are invested in one piece of machinery, and the company won't let a newly hired candidate crane operator ruin that.
Certification is like a driver's license, but it doesn't make you qualified. The next step is like getting a CDL. You have multiple classifications, but even if you get that, it is still up to the employer to qualify you for equipment you operate. The company has been having operators certified since the 90s. However, many of the certifying organizations are simply out to make a dollar- they want to make lots of money in a whole lot of time because of questioning of verbiage. The company's safety manager knew people on C-DAC, and sat down and read the preamble to the standard. Lots of good has come from standard, he said. B30.5 gives it more backbone, despite not being a focal point. But, you still have to go back and look at B30. It's the education process for small companies that lag behind the rest of the industry. 
One last thing on certification: if OSHA is going to go with capacity in addition to type, it will require an enormous expense to set up. Some organizations that say they can certify to capacity, but how are they going to do that?  Do they have a 500-ton crane to do a practical test?  How can you do that? 
You need to be qualified to operate the specific crane you're going to be operating, and it's on the employer to verify that qualification, regardless of what you're doing. The employer needs to qualify you to do your job.
II. Qualifying Crane Operators
The union doesn't have dispatchers here in the local area, only business agents. The local union is small; they know everybody, and the company is the largest employer in the area. The company probably knows all the guys working out of the hall, and knows what they can do. They don't take every operator that the local may have at the top of their list.
If they go to wind sites in Pennsylvania, they try to work 50/50 with the local there. That is, half of the operators will be long-term employees from the company, but the company will hire some local operators too. The safety manager will evaluate the new operators and use them at the level of skill or reliability they are able to demonstrate.  
The company typically assigns a person to a specific machine. They won't jump from machine to machine from day to day. When an operator is unfamiliar with a type of machine, is when they can get into trouble. 
OSHA: When an operator starts, or is hired, is there a formal process for evaluation and/or training?
A lot depends on the individual; even if that operator is known to the company, a representative of the company will still go out with the new operator to get to know their abilities. The company has approximately a dozen seasoned operators who have a high level of competency. They can get out on sites and make evaluations of operators. On occasion, the company has sent other operators back because they were not qualified--even if they had a certification card.
OSHA: How long does the company monitor new operators? 
That depends on machine and configuration. In general, with the large cranes, the company will make sure that seasoned people are running them. The company will "partner up" (i.e., mentor) newer operators with more experienced operators. If younger people want to learn the machine, they will put new people with the seasoned operator for two to six months. The length of time they're with that experienced operator depends on how quickly they learn from the seasoned operator and the on-the-job experience.
In regard to capacity:  trying to sort cranes by capacity, there are so many configurations it is tough because the crane can have basic boom, a boom for heavy lifts, a luffing jib, etc. When they get a new machine from the factory, the manufacturer will come and train several of our people. Then the company's people will train the others. 
Even though they're a union shop, the company considers their seasoned people their own employees. These days, they may take on someone, but with the current economic conditions, they had to downsize in 2008, especially in small crane operations, downsize 40-50 machines in 1 year, representing 25% of the total number of cranes. The company took that money and reinvested in larger machines and crawlers for use in the energy industry. 
The company won't always take the first name out of the union hall, not if they don't have right skills or attitude to be a safe employee. They don't have a lot of employee turnover.
OSHA: Why might the company turn someone away?
When they get an operator to come in, most union operators will be honest and if they've never run a crane that big, they will say so- that's the big sign. The worst scenario is the guy who says "I can run anything." You want someone confident in his or her own ability, but honest in the range of machines she or he is capable of operating. Bravado is one thing, but backing it up is another. You can tell many operators don't belong in a particular crane by observing the first swing of the boom.
The most important elements to assess are attitude, experience, and the practical test. Watch them operate the crane. That's what it boils down to. With seasoned operator, it may take a bit of time to switch between manufacturers, but the nuts and bolts are all the same. Can they control the headache ball?  Give them a few hours or even a day to acclimate to the crane. If an operator is as rough as a cob, he or she shouldn't be out there. It sounds rough, but for safety you need to make that call.
Some people start on wash racks, then move to yard loading and unloading. They will get rigger and signal experience and will then get under a qualified operator. That's how they bring young people into the trade. There are not a lot of young people in the industry, so they have to bring them in to work through the system. The company has gotten some outstanding operators that way. They are looking for people who "take pride in what they do."  The apprentice may work under a number of different operators in the learning phase. For instance, an operator will take an oiler and start letting the oiler behind the controls a bit to gain seat time, and then will let the oiler operate a small crane. As you move up the ladder- some want to continue, some do not. In the company, you'll go from 90 ton class to something that requires additional trucks for A/D, etc. Also, when you're moved up, you get a financial boost, because they provide transport, a company car to transport tools, etc. So, there is a financial incentive to move up in class (i.e., big cranes). 
OSHA: If the new operators seem fine, do you send them to easer jobs first?
In regards to hiring on a full-time basis, the company is in a niche market out of the halls. They know what they are going to get in regards to people. If it's a new person, they will do background checks and call references to find out what they've done. The company will start them on day jobs--which are smaller jobs -- and evaluate what they can do. The company will also send the new employee out on multi-crane jobs, so others can monitor him or her. 
On mobile cranes, operators must have a CDL. When going out of state, the company will sometimes get in the situation of bare renting a crane, and in that case, they are only leasing the asset. Their ED/AD guys will have Company B rent a crane from the company, and Company B will provide an operator. The company will have a seasoned operator that will spend some time with their guy, and if the company sees that their guy isn't able to work the crane, even if they have credentials, the company will raise a red flag with Company B. The experienced operator is not just handing over the keys, they're partnering with the client. If something happens, both companies are involved. It's a good business practice.
With a new guy, once the company has done a background check, he has gained construction and crane experience, and has started on small cranes, then he will then take on other projects, such as steel erection, where there is supervision. By monitoring them this way, the company will know if the new employee is good enough. If he is not, they will send him back.
OSHA: How long does the company monitor operators? 
They will continue to monitor the operators for a while. Every lift is different and assessment is done on an ongoing basis. The safety manager is to get out on sites themselves to assess operators, how they setup, how are crews working, and of problems or questions. The safety manager will talk to operators about these issues. The safety manager will drop by one of their biggest jobs once a week, just to pop in. In their taxi fleet, it can be hard to follow up on simple jobs, but the simple ones are the ones you need to visit in person. In many cases, the larger the crane the more attention is paid to details; it's the smaller jobs where the contractors don't even read regulations. They try to monitor the operator, and they will talk to contractor about safety, etc. so everybody goes home at the end of job.
They will see guys operate a big crawler on a big job for a year, where the site conditions are taken care of because it's a big job, the working conditions are good, and there is better overall planning. If you take the same operator and put him on an 18-ton boom truck where every day is different, different sites, etc., they can't do that kind of work because they're not used to it. Even though that operator worked his way up to a crawler, it can be hard to go back.
The construction contractors often don't respect cranes, don't understand the consequences of cranes, etc. There will be a superintendent on a site, and he or she may be a good manager, but they don't know crane operations. It's the exposure of running cranes in different sites and conditions- people don't respect the small cranes enough, and they can get into more trouble than a big crawler sometimes. 
The industry has gotten better, and the company attributes that to the push for certification that started in the 90s; there is the basic knowledge, and employers such as the ones the company works with are ensuring that qualified operators are on equipment. That's the biggest thing you can do. But certification is a bonus. The way it sits right now, it works as it is. On a NCCCO card, it will list the 4 classifications on it. It has the basic knowledge and testing criteria. In the end it, is employer's responsibility to qualify- you have certifying entities who will promise the world and qualification for a fee- but that is not the case, the employer needs to do that.
It may get to the point that the average person won't be able to afford to get all those certs. Right now it is one affordable test. The union will hold a 40-hour certification preparation course, and Travelers Insurance also offers 40-hour class to prepare for certification. At the end of the day, anybody can take the test and be certified, but you can't just come over here and run any crane you want. 
A conscientious employer will make sure that they qualify their operators- it may take 1-2 years, but they'll work their people up through the ranks. 
The company has 116 crane operators total, 170 operating engineers (including oilers, mechanics, etc.). They have quite a few who can operate any crane in yard safely. They have one 20-year veteran with loads of experience, but he is on a boom truck. He is qualified for other cranes, but is happy on a boom truck. 
The first truck crane was bought by company in 80s. At that time you never saw a computer in a crane, didn't know what two blocking was, etc. And that still happens as new equipment is brought in. Will have the factory people come in and train- that's just fair to the operator. You can't stick them out there without any support. The company has found that the manufacturer training has been successful.
OSHA: Have heard that certification is by type, especially for larger cranes, but even with boom trucks, operating systems are very different between manufacturers.
They are very different, and an operator can't just move from one to another. More cranes are coming with rotating cabs; the majority of cranes in the industry are in the 40-70 ton class, because there is more work available, so there are more of them out there than anything else. There's not a manufacturer here in the US; with Grove, 60-ton is the smallest, they're not manufacturing cranes below 60-ton anymore, just boom trucks. They're stretching the capacity of these boom trucks, and eventually they're going to get in trouble. The biggest boom truck is a 60-ton, and they saw in a magazine that someone is introducing a 70-ton. The company feels that is crazy. It has to do with the economy of manufacturing cranes.
OSHA: What about owner-operators? 
Don't know that much about them. They see a few running around the area, but not very frequently. From what they've seen, owner-operators seem to take more risk. In the industry the equipment is so expensive you seldom see a one-man operator. In the future, the company predicts more consolidation of the industry because of overall expense of equipment and the different regulations. The company doesn't see many owner-operators anymore. 
The people who don't know what they're doing are more in residential arena- that's where you see the smaller folks. When you get to a company that is medium-sized like their company (i.e., a large, small company), they are held accountable by a lot of entities contractually, and also being conscientious they make sure that the operators are qualified. 
OSHA: Do you keep log of seat time and work history? 
The company is moving towards keeping records on computer. Dispatchers have lists of cranes and operators assigned, and a schedule of jobs with details of the project and the resources needed. 
Customers constantly check qualifications of the company's operators, and new customers want verification that the operators are qualified on letterhead from the safety manager. Even during bidding process, general contractors want to know specific names, qualifications, certifications, etc. of all operators on the project. They are not happy about the extension of effective date for operator certification requirements. 
They are contractually obligated to do several trainings, but several of the company's employees just don't do computers. They may need help operating the computer. Testing is on the computer, but they do get all of them through it. Once they get it, re-certification is not usually a problem. Finally, operators are not allowed to use calculators on the written test. B30.5 stated that operators must have basic understanding of arithmetic, so no calculators. 
One can't really write a procedure of how to qualify someone, it's all knowledge and experience. One OSHA 10 hour course that the company teaches is on the crane standard, to make sure everybody is fully refreshed. They have a nice book giving an overview of Subpart CC. Another book details signal person and rigger requirements, and they are often giving that book out to operators. 
III. Crane Rentals, Bare vs. Manned
One of biggest problems in the Cranes and Derricks standard is that the smaller contractors have no concept of rigger or signal person qualification requirements and ground conditions. The company tries to educate their customers. In particular, the 10-employee companies don't understand the impact of these rules. They try to tell these companies; "because of the size of your company, you may not have to do recordkeeping, but you're bringing a crane to your site; so you still have to follow these rules."
Crane work is a serious business. Some think that it's lots of toys, and as recently as a year ago, the company had a bare rental 150-ton crawler on the contractor's site; the company representative asked the contractor about their operator for that machine, and was told that he was operating a smaller crawler, and had never operated something so big. The contractor didn't understand how that was a problem. 
When they rent their cranes out and the operator has certification, it is an advantage because the company has some "level of comfort" from a certification. It is comfort to know they've been through the process, but at the end of the day, it doesn't mean they're qualified. WV has state license requirements for crane operators- they recognize CCO certification, but they also want to see the individual grades and card to ensure that they understand the training. PA recognizes NCCCO certification as well. If you have that, they will accept you. In D.C., you must take their test. The company has operators who carry all 3 state requirements, primarily because on larger cranes, that's where they are most likely to work. The company is contractually obligated to different customers. The company renting the crane must make sure that the operator is qualified for that machine- and there is that language in the contract. Bare rentals run around 25% of revenue (and 50% of the number of cranes in their fleet); they don't bare rent the all-terrain (AT) machines, but will bare rent rough terrain crawl cranes. Very few lattice booms are rented bare. They don't bare rent mobile cranes. With ATs and truck cranes, the reason they don't bare rent is that the companies they rent to don't have qualified people to operate them. Most incidents happen at the beginning of a job, because people don't know how to work them. Contractors will take an excavator operator and will assume that they can run a crane.
A customer bare renting a crane must send certification of insurance naming the company as insured before the company will send a crane to the site. There is also a boom overload clause in the contract -- if you overload the boom, it is covered. 
The company is involved in steel erection themselves- the company started with the Owner's father and one bulldozer. The Father was an operator by trade, as was his Grandfather. The Father decided to go into business for himself, and bought a bulldozer. The company comes from small beginnings. 
The Owner started working as a teenager, and became a steelworker. Their company was built as a steel company, and they had cranes to do steel erection. They took the profits from steel and invested in cranes, now the crane business is bigger than steel erection. They built a local D.C. airport. They do a lot of government work in steel, and build hangars for the military. 
A majority of the crawler rentals are bare. They have about 40 crawlers, and would say that 75% are rented bare. One of them has been with customer for about a year; another one has been all over the Northeast. 
With some of the truck cranes, a contractor wanted to do some things that the company didn't agree with, so they took their equipment home. They've had some problems with mistreatment of cranes, but they have developed the whole process with how to rent them. They send a person with the rental, the other company signs off on the quality of the equipment at delivery, then the other company signs it back in at the end of the rental period, and the company does an inspection at the end of the job. Sometimes you do have to do repairs, cable replacement, work on the lattice, etc. Companies rent cranes bare because they only need to do crane work here and there; it's an expensive investment for just the occasional job. 
OSHA: Manned vs. bare, how much of the fee charged is for the operator vs. for the crane? 
Depends on the crane- when the company charges for the operator on a manned rental- for example, of 50-ton RT, in today's market is $7K month- with the lease crane only. If also operating and insuring, fueling, maintaining and costs of operator, then it's approximately $50 an hour, plus fuel and insurance for 176 hours / month  for an average of 22 days/month times 8 hours/day = $8.8K.
The regulations have helped the company; they don't have the losses and incidents that they used to have. In this economy, people are having a hard time, and are doing more operated rentals- people don't want the hassle of finding a qualified operator.
In current times, companies are choosing not to own their own equipment. It's a better financial decision to rent the equipment, so they really work in their niche, and sometimes do long-term bare rentals. Their customers have great comfort level with quality of their equipment, and with the experience and qualifications of the people that they provide. 
The company does a lot of non-construction work, such as at Northrup Grumman in Newport News and at Norfolk Naval Base. They have had cranes all over the country doing wind energy (not new construction, but maintenance of 80m towers). The company is also an MSHA-regulated company as well and knows the qualification requirements for MSHA. What are employee duties? An employee can be held directly accountable and can be cited. As can a supervisor. 
OSHA: Do you think that holding employees personally responsible is a good idea? 
"It would plumb up some of the stuff going on." The company cannot always be responsible for the actions of the employee. You qualify and train, but can't control an employee's thoughts at any given time. It's hard to explain, but "sometimes the employer can't be held responsible for the actions of an employee." 
IV. The Cranes and Derricks in Construction Standard
The company likes the standard as it is. It has taken some of the gray areas away, like ground conditions, and has clarified responsibility in multi-employer situations. 
All employees at the company have the authority to stop a job, and they are encouraged to call somebody if necessary. They are told, "don't force a bad issue." Customers understand this and appreciate it when they understand.
Interview #7- Canadian Certification Authority

I. Background
Representatives from a Canadian certification authority met with OSHA to discuss their experiences with certifying crane operators.  The province contracts an association to oversee the training and qualification of operators who run cranes within their province. Because of a shortage of qualified crane operators in this province, the authority was tasked to seek a reciprocity arrangement with other provinces and the US for certifications issued in both Canada and the United States.
II. Certification Program
This certification authority put together a program that verifies the competency of crane operators by requiring them to pass a written and practical test. The program provides for several certifications that vary by equipment type and capacity. To operate a particular type of equipment of greater capacity, the operator may have to get an advanced certification that also requires graduated levels of operating experience. Unlike crane certification programs in the US, this organization also tracks the working experiences of the operators it certifies. 
The most important elements of the certification system in this province are the hierarchy of 13 crane types, the 4 different levels of certification for each type, and the assessment required for an A level certification. The types and capacities of cranes that define the different certifications were negotiated with the crane industry (i.e., manufacturers, rental companies, and end users) and are based primarily on the top and lower end capacities of cranes of similar designs, configurations, and operating controls. The representatives from the certification authority alluded to that the manufacturers were in the best position to know where the capacity bands or limits should be for specified types of cranes available and their varying operating controls and configurations.
III. Crane Types
We begin with a discussion of the 13 crane type hierarchy, beginning with an illustration. (see next page)








Crane Types 

The 13 types of cranes specified by this province bear some similarities to those identified for supplemental requirements in OSHA's crane standard. The hierarchy of certifications is structured such that obtaining certifications for the more complex types of cranes also permits the operator to run less complex types. In general, operators who obtain certifications for cranes of greater lifting capacities are allowed to run cranes of the same type that are of lower lifting capacities. 
For example, an operator qualified for the lattice boom friction crane may run any other crane except for a tower crane. Tower cranes are considered to be so unique in design and operation that operators must demonstrate particular skills to qualify for certifications of this type. For example, keen depth perception, timing, and dexterity with the controls are critical to the performance of repetitious and time critical lifts that are typical of tower crane operations. 
An operator certified to run a lattice boom friction crane may operate all cranes except tower cranes and self-erecting tower cranes. An operator certified to run a 20 ton hydraulic crane or under, however, may only operate hydraulic cranes with capacities up to 20 tons. To further describe how the hierarchy works, an operator certified to run a 40 ton or less stiff boom crane may also operate a 20 ton or less stiff boom and all folding boom cranes. However, that operator may not run a larger stiff boom or any hydraulic cranes.
IV. Operator Experience Levels and Certifications
For each type of crane, there are four levels of certification available to crane operators (A, B, C, and D); these certifications reflect different levels of expertise acquired by the operator. The level of certification gives the employer some idea of what an operator is qualified to do with or without supervision of a more qualified person. 
Level A Certification 
This certification is the highest level available. It permits the operator to perform all functions of crane operation including critical lifts (critical lifts are defined by the certification authority, and are discussed below in the context of B level certification). To obtain an A level certification for a specific type of crane, an operator must pass an assessment offered by two testing groups specified by the certification authority. Operators must also complete an apprenticeship with an employer, but experienced operators from other jurisdictions may qualify to "challenge" the certification and forego the apprenticeship. The assessment is discussed in greater detail below. Along the way to the A level certification, the operator needs to hold one of the lesser certifications to use a crane and gain the necessary experience.
Level B Certification
This certification allows an apprentice or trainee operator to perform most tasks while under "indirect supervision" and critical lifts while under "direct supervision." Indirect supervision means oversight of crane operation by means other than direct observation. Direct supervision, by contrast, requires the supervisor to be close enough to observe and verbally communicate with the operator. Level B and level D both require the completion of an online "core theory" multiple choice test of 23 questions. 
Certification level B operators may only perform critical lifts while under direct supervision. Critical lifts are defined by the certification authority to include: 
   1. a lift by a mobile crane or boom truck that exceeds 90% of its rated capacity while it is lifting the load at a load radius of more than 50% of its maximum permitted load radius, taking into account its position and configuration during the lift,
   2. a tandem lift if the load on any one crane, hoist or other piece of powered lifting equipment exceeds 75% of the rated capacity of that crane, hoist or other piece of powered lifting equipment,
   3. a tandem lift involving the simultaneous use of more than two cranes, hoists or other pieces of powered lifting equipment,
   4. a lift of a person in a work platform suspended from or attached to a crane or hoist,
   5. a lift in which the center of gravity of the load changes during the lift,
   6. a lift in which the length of one or more sling legs changes during a lift,
   7. a lift by a crane, boom truck or hoist, supported on a floating base, that exceeds 90% of rated capacity for the lifting system,
   8. a lift of a load over or between energized high voltage electrical conductors, or
   9. a lift of a submerged load.
Level C Certification
Level C is a letter of permission to learn about crane operations. It allows the operator to operate the crane only when under direct supervision. No critical lifts are permitted for a level C operator. This certificate is valid for 6 months, and is intended to allow prospective crane operators to show whether they have the aptitude to move up to level B status.
Level D Certification 
Level D is intended for operators who use a crane on an occasional basis. It requires only a portion of the competencies required for level A. The employer is responsible for documenting the employee's skills and determining what lifts the employee is qualified to perform. The employee with a level D certification must be supervised during all lifts and no critical lifts are permitted.
V. Operator Qualification
The representatives from the certification authority explained that operators come to test that have varying levels of experience, some have many years of experience as an oiler, mechanic, or rigger during which they operated cranes in limited capacities. Others have far more actual seat time but may not have the familiarity with the system controls or configuration of a particular model of crane to be considered competent to run it. Other times, an operator may have years of experience operating a particular crane to perform particular types of hoisting jobs but that operator still may lack the practical experience to do a hoisting job that is new to him or her. Therefore, when determining an operator's competence to run a particular crane at the jobsite, the organization believed that several factors about the operator should be taken into considerations such as:
   * the operator's ability to take instructions and general demeanor, 
   * duration of applicable crane-operating experience, 
   * the types and configurations of equipment operated, and 
   * the types of lifts and activities performed with the cranes. 
However, the certification authority did not believe that a third-party testing organization could have enough types and capacities of cranes, or test sites for particular hoisting activities, to verify the competence of an operator to do all hoisting jobs under all of the possible construction worksite conditions. They did believe that a third-party certification could be developed to verify that operators could safely perform very limited hoisting activities using equipment of the most basic of crane configurations. Their program's lowest level certification (level D) does just that.
In sum, this certification authority was convinced that operator certification can be more for the employer than a learner's permit. It can be a driver's license if the limitations of the certification are specified and enforced by the operator's employer. Overall, the employer must ensure that the operator can safely run the crane at the worksite.




Interview #8- Large American Construction Contractor

OSHA conducted a telephone interview with the safety director of a large company primarily engaged in the building of residential homes. 
The company contracts out the work that is done on the homes to subcontractors and does not contract any crane work directly. In their residential construction sector, it is mainly the framers who contract out crane work, but occasionally site preparation or foundation work may require a crane. In the other work that they do, it is mainly concrete and sewer/storm drain work that requires a crane.
The company gives the authority for contracting crane work to their subs.  They are able to hire who they want, and who they feel is best qualified. The subs sometimes also hire other subs who may own/rent/subcontract any hoisting equipment needed to perform their jobs.
The company does monitor cranes and the work that they do when they are on the company's sites. Project monitors typically inspect the crane and the set up when on the construction site. The cranes are monitored for compliance to applicable regulations as well as general safety. The monitoring is done by walkthroughs by project managers. They always know when a crane is coming on to the site and will make a point of going down to look at it. The project managers can tell if the crane operator is not qualified just by looking at how they're operating the crane.
The company requires certification of any on-site crane operators and has done so for a number of years because they work in a state that requires it.  The safety director has been with this residential builder for 9 years, and there haven't been any crane accidents in that period.  Nor has the company had to send an operator or crane off the construction site due to safety concerns. Their subcontractors tend to hire the same crane companies frequently; so they are very familiar with the operators. They typically hire cranes with operators; sometimes those rentals come with a signal person.  Trusses are usually set by boom trucks.
The work that cranes are doing is mostly lifting roof trusses, but there is also some land development uses and precast concrete manholes and pipes that are installed with cranes. Pallets of material are usually lifted with an extended reach forklift, but those forklifts typically don't use any attachments such as extension booms/jibs or slings, just the straight forks. 
The safety director emphasized that site supervisors can tell when a crane operator is qualified by watching them operate a crane.  The company does inquire about an operator's training and requires them to be certified. Their framing sub-contractors tend to use crane operators/contractors who are familiar to them- they know who they're dealing with. More commonly, the company subs hoisting of roof trusses to the truss manufacturers.  A truss manufacturer may sub that work out to a carpenter, who then will contract out the crane work. 
Owner/operators: Framing contractors rarely purchase their own cranes -- the company's representative only knows of one framing contractor in Virginia that has a crane. The company doesn't do work with that framer.
Interview #9- Utility (Power Lines) Workers Union

I. Introduction/Background

OSHA staff met with a representative for an electrical (power lines) workers union to better understand how the electrical industry (both contractors and utility companies) ensures that union members who operate cranes are qualified to perform that work. 

The union represents workers in the utility industry (electric, gas, etc.) and contract workers who perform work on utility-controlled properties.  The arrangements and organization of utility employment versus contractor employment is totally different.  In general, the utility industry has a much easier process in place to ensure that its employees are qualified to perform work because the utility company works with individuals from hiring to termination, whereas the contractors are working with different union members all the time, job by job in many cases.  As a result, the utility companies have easier accessible tools in place to ensure individual employee qualification.

The contractors and utility employees perform similar work.  However, contractors perform more construction activities (construction of new power lines, for example) whereas utilities perform more maintenance.  For example, setting a power line pole because it is broken (maintenance) or installing new pole (construction) is still the same work with the same hazards and same equipment.  Because even contractors performing new construction may perform some tasks that qualify as maintenance, contractors will usually follow OSHA general industry requirements for line work since this is the stricter standard.

II. Types of cranes used in power line work

The union representative asked OSHA to consider how the electric power and distribution industry uses cranes in the context of the training that persons who operate the cranes receive.  The cranes they use are:  boom trucks, mobile truck-mounted hydraulic.  Digger derricks are exempted from subpart CC for power line work. Electrical line work uses cranes in a limited number of ways (with possible exception of building substations) (descriptions correspond with photos).  The point is that there are not a lot of different crane tasks or applications in this industry, compared with the many variations of lifting loads that occur on a construction work site.

Descriptions of cranes in photos:
1: A boom truck is used to lift a new pole and/or remove an old pole in middle of a right of way 60/70 feet up in the air.
2: A digger derrick is used for lifting poles to heights of 35/40 feet.
3-4: A jib is used with an energized conductor, 345kv, to hold up the line as secondary protection, while an insulating link is used as primary protection (this link insulates 100 kv per foot  -  the links we have in the subpart CC standard for proximity work are only 35 kv (neighborhood voltage)).
5: Different structure, same application: A boom truck is used and a lineman is hooking an insulated stick to a wench line  -  this is something the lineman would do manually  -  again all in right of ways.
6: To replace an entire structure, 2 poles and cross arms on4 trucks, all with the booms attached to the conductors, are used.  Then a digger derrick is used either to set new poles or remove old poles.  In this scenario, it is very possibly the person operating the digger derrick lifted the cable on all of the trucks because no one is in any of these trucks.  They are just used to hold up the line.
7-8: A similar type of boom truck is used -  this one has a robotic arm.  A company devised this arm - an attachment piece with 3 little arms  -  that can manipulate up and down, top and bottom also go up and down.  Different rated insulators mount to the arm. This is attached to all three phases on a power line to move them out of way.  It can be attached to a boom truck.  Linemen will take 2 of them and move the lines out of the way, then take down and put back up a structure/replace a structure without de-energizing  -  therefore they don't have to reroute load, so it takes hours rather than days to replace a pole.  This is a very efficient piece of equipment (different sized insulators, load limitations, but works well, easy to use).  (Structures are usually built in pieces on the ground, bolted together in the air).
9: Picture of a typical piece of equipment that linemen use  -  a basic boom truck.  During rulemaking, this union suggested an exemption up to 60 tons for this kind of truck.  This equipment doesn't dig holes.  It is just a lifting device.
10: Same equipment with 2[nd] configuration, rear mounted verses front mounted.
11: A knuckle-boom crane is used in ductwork for setting / building.  These are used both to lift and assemble, and they are getting bigger and stronger, very versatile.  Utilities like versatile equipment because they can be a money saver.  They can also set poles with these cranes.
12: An example of crane work can be found in New Jersey on I-95 near Trenton.  This is the installation of a fiber optic cable using cranes with extensions to lift cable up together without worrying about all the other stuff/traffic/obstacles (Tandem lift + buckets for the personnel).  This method avoids problems; it is not cheapest method but maybe the most efficient way to solve the problem without disrupting traffic too much.

Use of remote controls (especially with digger derricks) is becoming more common because it removes the touch potential hazard (i.e. the electric potential if a boom touches or comes too close to a line).  The operator often climbs on and off the vehicle.  At some jobs, the operator's job to sit in crane all day versus a smaller crane job might require people to climb on and off of the crane constantly.  Tools and equipment for building the power line will need to be removed from the truck bed. The operator can often be a journeyman lineman, and faces a hazard working around energized parts.  There are fiberglass parts on the crane but there is still a lot of metal.  Remote controls abate the hazards from step potential (on the ground) and touch potential.

Bigger, multi-purpose equipment is becoming more common. Today, in many instances the preferred piece of equipment is a boom truck rather than digger derricks, because it can be set up one time with a 100-foot boom and reach a lot of things.  So one piece of equipment can do the job that would require multiple pieces of smaller equipment.  Contractors are also more often choosing 60- rather than 30-ton cranes because they have more capacity with the same footprint and a longer boom, and therefore there is no need to have additional equipment.

Contractors are also using pin-on platforms and buckets to hoist personnel (although for CC, the employer must demonstrate that it is not feasible to use some other method- this is issue currently in industry).  The ability for abuse (and violating personnel hoisting requirements) is much easier with the versatile equipment, but these kinds of equipment save costs.  A large electric utility was cited recently for using a boom truck as aerial lift on the job.  Although this is being challenged, an "infeasible" argument is difficult since there was an aerial lift on site.  OSHA's refusal to allow a pin-on platform was a reason that this union contacted OSHA advice on whether such a platform could be used without demonstrating infeasibility. Another trend is employers [or manufacturers] attempting to qualify vehicles (all of them) as aerial lifts.

Another piece of multipurpose equipment is a forklift that has an auger and pole lifting attachment  -  it can be used to set 1200-lb. poles.  (Not clear what certification requirements would be).  

Contractors are building more transmission lines and distribution lines now; so they can afford to buy their own bigger equipment.

III. Lineman Qualification/Training Requirements

The union representative believes that training requirement for electrical work under 1910.269(a)(2) is a good model for qualification doing any kind of work.  He understands this requirement to have 4 steps:

	(1) train individuals to perform task (how to do it)
	(2) teach individuals what are the hazards of the task
	(3) train individuals how to mitigate hazards, and 
	(4) require individuals to demonstrate the proficiency to do all three.

Also under 1910.269(a)(2)(iii), if you haven't performed a task in a year, you are no longer qualified to do it; so annual review and re-qualification, and possibly re-training, of employees' abilities are required. Some things are obviously easier to re-qualify for than others.  For example, to re-qualify an employee to climb a pole, you can watch them inspect the tools, get on pole, and perform skills on the pole -- this is relatively simple.  

In this field, book work plus on the job training (OJT) = qualification.  Both are vital, but OJT may be more important.  

Utilities: 

The employer keeps track of who is re-qualified, which is why it's a much easier process for long-term employers (utilities) than contractors who work with employees for a shorter time.  At first the industry didn't like re-qualification, but the utilities appreciate the process now that it makes for more skilled employees.  

Contractors:

Contractors hire employees who have completed the union apprenticeship program for specific jobs -  the same registered national apprenticeship program applies coast to coast.  There are area training centers that are responsible for the training program for an area; however, line work is performed in different parts of country with different techniques.  For example, on the east coast, work is performed more often with rubber gloving techniques on live wires, while in the west, live line tool work on the live wires is more common.  Union members have a "ticket" that defines their status (i.e., apprentice v. journeyman).  

However, how does the employer determine that employee's qualification for a particular task, such as crane operator?  Construction local unions will often have a qualifying test for lineman skills to pass to be on the "A list" to get jobs.  There are also union networks  -  two nearby locals might audit each other's test and offer reciprocity on membership testing.  Union training program participants receive a card that is a validation of certain amount of training  - training includes testing. There is no special job-based classification for the union workers who are assigned contract jobs  -  they are all linemen.

IV. Training Operators to use Cranes

Utilities:

The process for utilities to train crane operators can be easier than the process for contractors to accomplish the same.  The program with new hires in utilities is not so much an apprenticeship as a 63-month training program for a line man, with what may be an additional 24-month training program for a digger derrick/ crane operator.  There are progressive steps, training and efficiency checks/tests.  Entry level utility employees may or may not have prior training/testing.  Utility workers are generally not jacks of all trades, but rather certain employees might learn to operate cranes by becoming equipment operators (to include digger derrick, bulldozer, and crane).  Utilities typically have a long list of different job descriptions/skill sets for their employees. 

Contractors:

On the contractor side, this would be pretty much the same thing, but just less structured/organized.  During an apprenticeship, an apprentice would certainly not be allowed to operate a crane in a dangerous setting.  Everyone is on and off digger derricks and boom trucks developing skills, but not for critical lifts.

If, for example, an apprentice was on the job, and the contractor's workers are holding up an energized conductor  -  the apprentice will not touch the controls.  This will be a journeyman with experience who is qualified to operate the boom truck.  However, in a different setting, setting a pole for example, the apprenticeship program will give him or her some experience operating the heavy equipment.  The apprentices are also simultaneously getting training that is specialized to line work  -  work rules, voltages, rigging when they can go up the pole, etc.  

Crane- related apprenticeship program training:

A "Step 1" apprentice is not going to be on a boom truck.

Relevant training during the apprenticeship will include limited load chart work, but probably it ought to include more.  Grounding is a big training topic, rigging as well, but not specific to boom trucks and digger derricks.  With so many types of equipment out there, training is not that specialized.  It perhaps should include examples of how to read load charts, a module on different capacities, and how to read and apply charts.

Apprenticeship training is focused more on where the accidents in line work are occurring, while crane events (tip overs, etc.) are not usually the accidents that are happening in line work.  Usually it's due to contact with an energized line.  The digger derrick makes contact with the line.  Setting a pole in energized conductors is probably the most dangerous part of lifting jobs.

V. Paring Operators with Pieces of Equipment

On the contractor side, where bigger equipment (specialized or larger capacity cranes) are needed, many contractors will either hire an operator to go with the crane where it goes or internally send someone to school to get qualified to operate that big piece of equipment (the manufacturer training, for example, although it will only teach set up, maintenance etc.) and certified to meet the OSHA standard (now).

On the utility side, the employer would often just rent the big equipment and contract it out.  If the utility does have a larger crane, dedicated employees will operate it. 


VI. Crane Certification verses Qualification

The union representative provided examples of 10-day classes for mobile crane operator qualification, which would result in a card that says the individual is a qualified mobile crane operator, as opposed to just certified.  This kind of training includes more "on the job" and seat-time training than the certification program.  However even after this 10-day program, it is not clear how "qualified" they are.  He was also aware of courses in crane training and qualification that lasted as long as 4 weeks.  

A big difference in this kind of class is there is practical as well as written training, and the practical part is much longer and more meaningful.  It was at OSHA's stakeholder meetings where this union representative first heard that certification was essentially a "learner's permit."

An operator's certification card is viewed by some contractors as the operator being "qualified" under the current standard.  The contractor will typically still observe them, but consider the requirement of the standard to be satisfied.

Utilities can be somewhat different than the contractor because they can take more time more to verify that a worker is really qualified, whereas contractors must staff or hire job by job, so time is of the essence.

Certification was good in theory, because there is some training and written plus the practical.  
That is more than was previously required, but it is a scrunched down to a mini version.  People really can't learn just from certification/classroom.  They need on the job mentoring, demonstration, and practice.

The union faces this everyday with the "lineman ticket." Traditionally, the journeyman lineman is qualified to do everything, but this is changing/has changed.  Same with riggers--this is becoming more specialized as riggers require more specialized skill sets for different jobs.

Training is ongoing  -  like in 1910.269(a)(2)  -  reviewing abilities every 12 months if necessary -  one card can't last forever.

VIII: How do Contractors determine whether a Lineman is qualified to Operate a Crane and what can they do about someone with questionable qualifications?

To work on a line job, an individual would have to join the union, regardless of background.  There is not a specialized classification for crane operators within the union. When a new member or employee is sent out to a job, especially one that has not completed our apprenticeship, someone will observe this employee and determine qualifications. In some cases, a lineman may be sent to one of the crane operating schools discussed above.

Most apprentices are going to be given exposure to operation (at least pile driving/digger derricks), but there are plenty of linemen that are not going to operate a crane.  

When a contractor is given linemen for a job, they decide who does what task.  

In our contracting industry, the foreman is a union member and a journeyman lineman plus there will be safety guys and other managers.  Also if something goes on, maybe a contractor could get black listed from the utility property.  So there is an incentive for the contractor to be safe/ensure the safety of the people working.

There is no central system for tracking records of union members.  Although there is no formal logging process for bad or good stuff that happens to a union member, if something happens, everyone knows immediately and there are websites that post these details as well.  Some contractors will refuse to hire or use certain people, but if the union members are on the books, the union still has to offer them work.

Local unions all have a trial board, and charges against members occasionally could be based on safety issues for which the penalty would be expulsion, retraining, fines, etc.

When a contractor needs someone for a crane job, they request the union to provide a qualified (now certified) person.  Certification is changing employers' sense that qualification still matters.  Some contractors believe a card for certification is enough.

VII. Type and Capacity

Type and capacity does matter -  if you are on a 20-ton telescoping boom and lift 8,000 pounds, versus 80 ton, lifting 30,000 pounds, that is a huge difference.  Different operating systems would make a difference in cranes as well.  Smaller cranes are using more sophisticated operating systems.

VIII. CDLs

A candidate apprentice must get a CDL driving license to get into the apprenticeship program (CDL has a learner's permit now).  Federal DOT rules control CDL, and can be supplemented by states with extra requirements.
Interview #10- Equipment Operator Trainer- incl. Multi-Purpose Forklifts

I. Background
On July 25, 2013, OSHA staff spoke with a provider of forklift training in on the US east coast. The training company trains operators for forklifts, aerial work platforms, and earth moving equipment. The discussion centered on hazards created by attaching a boom and winch to a forklift, and where operator competencies are frequently deficient. The company sees rough terrain forklifts with boom attachments being used more frequently to hoist building materials at jobsites. However, it is questionable whether the operators have been properly trained and evaluated to verify that they can safely use the forklift in that configuration. 
II. The Training Course: Matching the Training to Equipment Used
The training company puts new operators through formal instruction followed by a training course intended to match the requirements of § 1910.178(l). The company certifies operators for forklift classes 1, 4, 5, and 7. The company provides up to 7 levels of forklift certification based on the design of forklift and the complexity of the lifts. The company's representative explained that one obvious difference between the operator assessment they provide and that of most employers is that employers often do not challenge the operators to solve problems related to conditions at the worksite, the parameters of the lift, and the center of gravity of the forklift. The employers' assessments are usually focused more on the operator's familiarity with the forklift's controls and to command movements of the forklift under ideal ground conditions.
Following successful completion of the company's training program, the new operators receive a signed and dated certificate indicating the equipment they are qualified to operate. The certificate indicates whether the forklift is a warehouse type or rough terrain, and vertical reach or mast. Once a new operator is certified, he or she is competent to inspect the equipment, read a load chart, and operate the forklift on a job site. However, the training company reiterates that the employer must ensure that operators are competent to do the types of hoisting jobs performed at the job site.
The training company doesn't document attachment qualification. When teaching someone to use an attachment, the trainer explains the attachment's capabilities, especially the range of operation.
III. Evaluating an Operator
The training company first evaluates the operator's knowledge of the equipment and challenges the operator to verify that various loads are within the lifting capacity of the forklift in that configuration. It is essential that operators are able to make determinations at the jobsite regarding the capacity of the equipment. Next, the operator must be able to inspect the forklift for deficiencies and understand what hazards the deficiencies present to the operation of the equipment.
Once the operator is in the seat of the equipment, the evaluator observes how well the operator appears to be familiar with the controls of the forklift. Other things--such as whether the operator immediately uses the seatbelt, rotates the forklift in the right direction when working forwards and backwards, and checks to the rear and lift the forks before moving--may also be indicators of the operator's familiarity with the forklift. The operator then must be able to safely handle loads and understand the hazards of performing various types of lifts and configurations of the forklift. The company's representative was concerned that too many employers were not taking the time to ensure that operators practice and become skilled at handling loads with boom and winch attachments before assigning the lift to the operator in the course of a workday.
IV. Issues Created by Crane-like Forklift Attachments
One issue created by the attachment of a boom and winch to a forklift is that some attachments don't match up perfectly with the crane they're attached to, and may not even come with a load chart developed by its manufacturer. The company's representative has heard many stories about employees not knowing how to use a load chart at all, or how to do calculations that would verify the diminished capacity of the equipment once equipped with boom attachments and suspended loads.
The ease with which a forklift can be modified to produce crane-like operation is an issue when changes to the load chart or adjustments to the amount of counterweight have not been done. The training company stated that boom and winch attachments are among the most dangerous forklift attachments. The company's representative believes that one way this operation can be made safer is through the use of a lift plan to guide operation. When the employer develops a lift plan, factors such as the extended reach, the weight of the load, the height of the lift, the leveling of the forklift, and specific worksite configurations and hazards, become more evident and can be addressed well before the lift is attempted.
V. Other Concerns of the Company
Potential lack of supervision- Many employers will pay to have all their forklift operators trained, but not maintain a skilled supervisor on staff. Therefore, there often aren't many qualified operators in supervisory roles.
Engineering- Most forklifts with boom and winch attachments used in the US have no system in place to prevent them from lifting too heavy a load. In addition, the boom and winch attachments may or may not come with anti two-blocking devices depending on the manufacturer of the attachments.
General Operator Training- Many companies aren't doing enough to qualify forklift operators. They will just show a video followed by a quick drive around.
Interview #11- Large American Construction Contractor Firm

I. Introduction
OSHA staff spoke with the safety manager of a large American construction contractor firm based in Texas. The safety manager has over 30 years of construction and crane safety experience, and holds a range of certifications. He was also a subject matter expert (SME) for two of the crane operator certification organizations, and remains a SME for one of them. He served as a SME for the other for 9 years. The company owns approximately 120 cranes that range in size from 4 to 450 tons. The company employs 150 full time operators in long term employment. These operators are not routinely certified by third party organizations, but when a client requires it, the company will seek certification or assign an already certified operator.
II. Qualification for employees
a. Qualifying a new or existing employee without prior operator experience
To qualify a new employee as an operator, the company begins with training on safety law and manufacturer's recommendations. This study is supplemented by work around the crane to assist in familiarization. If that employee shows promise, the company will give him additional material to study, and start him out on small 5 to 8 ton mobile cranes used in refineries. These cranes are very small, have short booms, and are difficult to tip over. 
These small cranes have their own written and practical exams (developed by the company) that the employer requires the operator to take to become fully qualified on them. Successful completion of the written will enable the new operator to move on to the practical. The practical exam follows the aforementioned study of work safety rules and manufacturer recommendations, as well as supervised seat time culminating in the written exam.
This process normally takes about 6 months for quick learners. Once someone is qualified on one of these smaller cranes, there exists the prospect to train further and move up to larger machines. Once qualification is complete, the operator is issued a license indicating the capacity and type of crane he or she is qualified for. That license is only valid at the company and does not expire. Though the license doesn't expire, the operator will be reevaluated after three years. The company does not seek third party certification as a matter of routine. Third party certification is discussed in more detail below.
b. Assessing a newly hired operator's qualifications
When a new operator comes to the company, he starts by listing his previous experience with different capacities and types of cranes, what employers he worked for, and how long he worked for them. The company then uses the written and practical exams to verify the qualification indicated by the new operator's work history. If he or she fails either the written or practical test, the operator will not be employed. Upon successful completion of the aforementioned tests, drug tests, a background check, hazcom training, and some new employee orientation, the new operator is given a non-portable, or company, license that indicates the capacity and type of crane(s) he or she is qualified to operate.
c. Qualifying an operator on a new crane
If the company has an operator who is already qualified on a given crane and needs to move him or her to a new type or capacity of crane, the company repeats the in-house testing process. The company has capacity bands that determine the range of equipment within a given type that an operator may operate. If he or she needs to move outside that capacity band, training and testing must occur.
d. Role of third-party certification
The company representative views the in-house program as sufficiently robust, and believes that third party certification doesn't add much to their program. However, some clients want only third-party certified operators for their own purposes, so the company will have the operators certified when that is an issue. The company is an authorized testing site for one of the certification organizations, so the practical portion can be done at the company's site with the company's own cranes. 
The representative worries that the third-party certification can short circuit training, since some believe that if someone has a current certification, that nothing more needs to be done. Qualification requires continued education and training. Insurance companies, at least in the representative's experience, haven't been requiring the company to use certified operators. The representative also worried that certification could cause training to be too focused on successful completion of the test instead of holistic crane experience that prepares the operator for a wide variety of situations. 
III. Crane Rentals
The company occasionally rents cranes when they have a project far away from their home base. Typically they use their own operators when renting a crane, and seldom bare rent. He knows that some people want crane rental companies to be required to offer training when they bare rent a crane. 
IV. Opinions on the Delay and Capacity
The representative and other actors in the region feel like they're being punished for having their ducks in a row. They proactively went and certified operators, only to have it no longer be required for their competitors who weren't as diligent. The representative also believes that capacity is important in crane certification. That is reflected in the company's in-house program. Capacity is the clearest way to distinguish between different cranes of a similar type, even if capacity is often a function of the crane's configuration.
Interview #12- High-Volume Home Builder

I. Introduction and Background

OSHA contacted the safety director of a high-volume homebuilding company on the west coast. The company has employees on site to schedule and coordinate a sequence of construction activities performed by a variety of tradesmen who are subcontracted for their particular expertise. The representatives of the company play a role in ensuring that no one gets hurt, but are not employed as or expected to be experts in each of the trade's activities. The company's representatives at the job site do encounter cranes being used and can often positively influence the safe use of that equipment. The company currently has limited means to verify that crane operators are certified other than by the general set-up of the crane and if the crane appears to be operated in a safe manor.

II. Cranes Used in Residential Construction

The company does not own or rent any hoisting equipment, but does subcontract to employers who may use cranes or in turn subcontract to framing companies that may use cranes and all-terrain forklifts to frame residential structures. The safety director explained that most of their contractors are often small crews that will stick frame or erect panelized wall frames and may at times even set trusses by hand instead of using a crane. However, some of the larger framing companies contracted may own or rent cranes for these purposes.

Cranes may also be used by material supply companies to deliver building materials to residential structures that are in various phases of construction. Most of this equipment is low- capacity boom trucks or flatbed trucks unloaded by forklifts. The building materials are delivered to the ground and left in bundles to deter theft of the materials. The supply company generally employs the operators of this equipment; some may be employed by larger contractors who deliver their own building materials. The safety director also believed that some contractors would, at times also rent the equipment and an operator from an equipment rental company if needed.

Because of space restrictions on residential construction sites, it is common to see all terrain forklifts used to hoist and handle building materials and structural members. The safety director did not recall ever seeing all terrain forklifts being equipped with a winch and hook and used on its construction projects to hoist building materials. When loads are hoisted by forklift with an extension attachment using a sling, the subcontractor may be asked to confirm that the manufacture approved the configuration of the forklift with an attachment. If something seems wrong with the use and operation of the equipment, the contractor may be asked to verify that the operator has been trained to do that job with the equipment used on that site or the work will be stopped.

III. Where Do Subs Get Their Operators

Most framers no longer find it cost effective to maintain cranes and employ crane operators on staff, if merely due to large fluctuations in available work that can occur over the course of a year. . More often equipment will be rented and the rental companies will provide the operators. Contractors tend to use crane providers they are familiar with and stick with those providers who are not only good but are also safe.

Since the company does not operate cranes, its employees learn enough about cranes to be able to tell when there is something obviously wrong with the crane's set-up or the way it is being operated. However, the company's interactions with the crane operator working for a contractor are often minimal because:

   * the company does not own or rent the cranes
   * the company's site supervisors are not certified or qualified crane operators.
   * the company has very limited direct control over its sub's and their subcontractors
   * contractors are experts in their crafts and, in general, will be more knowledgeable then the site supervisor would be in respect to their trade. 

IV. Role of the Company in Ensuring Safe Operation of a Crane 

When managing the production schedule, it is possible that the site supervisor could observe things like:

   * a crane operated too close to a power line
   * load being hoisted over personnel
   * set-up of the crane such as outriggers not deployed or improper barricading of the operating area. 
   * loads not handled in a controlled manner.

When something does not look right regarding the operation of the crane, the company's site supervisor will ask questions of the contractor and the crane operator to try to verify the operator has been trained and certified in the safe use and operation of the equipment.  Since the company's site supervisor is not a qualified crane operator, verifying that an operator has been trained and/or certified in the operation of the crane may be as much as the site supervisor is able to establish 

The company's safety director views current certifications as a validation of the crane operators' basic knowledge and skills, such as being able to read a load chart, understanding operation and use of controls, and proper set up of the crane. The employer must still ensure the operator is familiar with the crane. The company does not have the expertise to assess the qualifications and skill the operators, but does train its own employees to recognize worksite hazards and some of the hazards related to the operation of a crane. 

Most of the time, just having a contractor take time away from working to explain questionable work practices is enough to get that contractor to correct the situation or just find a safer way to do the job. In addition, the company can also bill its subcontractor for repeated safety issues and delays in the construction sequence. As a final resort, the company can request that its contractor have the operator replaced and that would be done if it appeared the operator was not going to work in a safe manor. The company focuses on preventing injury and property damage while remaining productive. The company's primary safety goal is injury prevention not compliance with OSHA standards.  One would hope these would go hand in hand but injury prevention must be the priority.

Interview #13- Major International Crane Manufacturer

I. Introduction
OSHA participated in a conference call with a major crane manufacturer. Participating in the call were three of the company's employees: one employee was a product safety manager, the second was in the Safety Department, and the third was a product safety manager based in Europe.
OSHA began the call by describing the background of Subpart CC and the current investigation into the issues surrounding operator certification and qualification, as well as the issue of type and capacity in operator certification.
II. Company Background
OSHA: Does the company have operators for the cranes that they manufacture? What is the process for training and qualifying these operators?
Company: In their facility where all-terrain cranes are built, they do employ people to set up and operate the cranes. However, the employees are performing repetitious specific lifts within strict parameters, and these lifts don't really come close to replicating the range of conditions found on a construction site. The lifts are intended to ensure that the newly built cranes meet the design specifications. The ground conditions are not an issue, as the cranes are set up on touch pads.  There are no power lines, and they know the machines well.    
When the company is developing new cranes or new lifting accessories and attachments, the operators who test these products typically have more experience; for example, they know what to look for relative to what the engineers want to see.
There are also the product support/field personnel who are sent out to assist customers with familiarization training and lifts. They are not operators, but they do provide information on the crane and proper lift mechanics for customers.
This structure is also applicable to their manufacturing operations in Europe. They provide some user training, and provide specific training on crane models to customers. They also work with the accident insurance provider in Germany (a government entity) to provide training to crane experts. 
It doesn't matter what you are operating, there are certain things on a jobsite that an operator needs to know. Someone else may do the lift plan, but the operator needs to verify the ground conditions, etc. This needs to occur regardless of the size of the lift or type of crane. The company has been attempting to harmonize control schemes across models, so it will be easier to operate various models. However, different cranes can have different ground condition requirements, and the company does believe that qualification needs to be type specific.
The company manufacturers almost all types of cranes. Mobile trucks, all-terrains, tower, etc. They have 500 different models available. 
III. Regulatory Schemes 
OSHA: As an international company, do you find that any particular regulatory scheme works better than others?
In Germany, they do not certify or qualify crane operators; the regulating body does that, and they primarily certify on theoretical knowledge. Operator certification is not mandated--it is strongly recommended. Certifications exist for crane operators, crane experts/investigators, and the metal and wood industries. The accident insurance provider does have the authority to shut down unsafe worksites.
In the rest of Europe, it depends on the country. The European Association of Abnormal Road Transport and Mobile Cranes (ESTA), the crane user association, is working on a project to establish a European-wide certification scheme, and they are in the process of collecting information from each country. Some European countries have mandatory certification, some do not, and training content can vary widely. Outside Europe: in Singapore, certification is mandatory, but they do not certify by type, they certify by manufacturer. 
IV. Operator Training & Qualification
In the US:  	
At the company, they have operators testing new products for adherence to design specifications. They do not have their operators do commercial work, and those operators are qualified to ANSI B30.5 standards. They do not believe that they are certifying their operators.  Because they are not in construction, they are not required to certify them. Their operators who work in repair and refurbishment are trained and qualified to the same standards/level as the operators engaged in testing new equipment. 
The company has several operators who have been with them for years and are very experienced. Training is a focus at all of their facilities. They can't say exactly how new operators are trained, but they will ask their quality manager to share that information with OSHA.
Their customers, on the other hand, operate machines for very long periods of time, much longer than the manufacturer's operators, and know their machines very well. They also operate their cranes under very different conditions, and in situations that the manufacturer will never encounter. Customers are also using multiple manufacturers' cranes in many instances. 
OSHA: Is the company aware of the ways that customers train and qualify their operators?
Sometimes. Some customers self-certify, especially the larger companies, like large oil companies. In other cases, they go through state and local operator's unions. It really is all over the map.
V. Crane Accidents 
The company supports operator certification. There is a lot of discussion of certification and qualification with every accident that happens involving one of their cranes. They get reports of incidents, and many times, it is either the operator or the lift planner who were not doing what they needed to do, and with negative results. In an all-terrain crane, you don't often have blatant operator error. With small boom trucks, that will occur--you'll see an accident where the operator really didn't do his or her job. With these smaller cranes, you'll see the less experienced operators, and with less experience, usually comes more trouble. The accidents don't have a lot to do with capacity.  Boom trucks have limited capacity, and they're not performing complex lifts, it's more to do with operator inexperience. 
Big lattice boom crawlers are typically operated by the most experienced and safest operators.  These cranes are very expensive and cost several million dollars. They lift multi-million dollar materials as well; so there are huge consequences that come with accidents. The larger the crane, the more focus on safety.
One other factor in safety is that with the bigger cranes, you see one operator is assigned to one machine.  It becomes "his machine," and that operator becomes very familiar with that crane. With the smaller cranes, you may see operators jump from crane to crane.
Another factor is the element of maintenance and inspection of cranes: Often even very good operators do not know how to properly inspect their crane. 
Looking at accident history, from time to time an accident's cause will point to maintenance. From a general safety perspective, regardless of type, an operator should be familiar with the daily inspection requirements of their crane, and should know what to look for. 
VI. Monitoring Systems
OSHA: Are monitoring systems installed on cranes as a method of tracking them? 
These are telemetrics that are usually customer-installed, but they don't usually record data that would be useful in an accident situation. They are mostly used by customers for fleet management; maintaining their assets, tracking service schedules, etc. 
The company's cranes do have an event recorder (also known as a "black box" in planes) on electronic control system machines. These recorders record a change in state. If there is a change in state, i.e., a fall or an overload, it records that. But it does not transmit that information, and the information is "first in, first out."  Once the memory is full, the oldest data will be overwritten with the newest data. 
Customers can't download the information from the event recorders themselves; a tech can come out to their site and download the data, and that information can be provided in an accident investigation, especially if investigators want to know the condition of the crane at the time of the event. 
Tower cranes have a data logger, which can record more information. 
The company does have accident report procedures for when one of their cranes is involved in an accident. They get copies of documents related to every incident that they hear about, in case of any allegations of malfunction. Each manufacturer takes care of accident reporting in their own way, but that information is kept internally to the company. In certain markets, sharing accident information might raise the litigation risk. 
VII. Variance between manufacturers in regards to controls 
Standards are being written in the US that will specify that certain controls will be located in certain locations in the cab, as well as the direction of control movement in relation to the direction of the crane's movement. They are using concepts called "zone of reach" and "zone of comfort" to ensure that controls are put in locations where they are comfortable for operators to use them.
With boom trucks, the controls are all standardized across most manufacturers, so an operator can switch machines without much difficulty. The differences between them are comparable to the cruise control buttons in your car.  The location and look of the buttons might be different between a Ford and a Toyota, but the application is the same. 
With all terrain cranes, manufacturers are starting to harmonize cab and operating control systems across capacity. Even amongst manufacturers in Europe, they are trying to have some common, consistent safety protocols.
They can standardize controls, but operators still absolutely need to know the specifics to the type of crane they're operating. They will always need to certify/qualify/train to type.
Interview #14- Residential Home Builder

I. Introduction
OSHA spoke with a residential homebuilder located in the Midwest. The company uses cranes in construction, and OSHA spoke with a company representative. This homebuilder does not own cranes or directly employ operators. However, this employer's representative indicated that they rent cranes with an operator when needed.  
II. Assessing the operator's qualifications
Generally, the only indication of operator qualification available to a company renting the crane and operator is the certification. The employer's representative believes that the capacity and type framework was a good way to indicate that the operator was qualified to use that particular crane. Most operators that the company deals with are certified, with only one rental company being the exception to the rule. Once the rental company is on the company's work site and using the crane, the company's employees will observe operation of the crane to ensure that it's done in a safe manner. The company's employees are the ones in the zone of danger when the boom starts swinging around, so it's important that they be aware and observe operation.
III. Experiences with unqualified operators from crane rental companies
The company has had unqualified operators provided to them. The company will document the operator's name if they think he or she is unqualified, and ask for a new one for that particular job. The company will not use the rental company again if they send an unqualified operator. Near misses are also documented, and sometimes result in immediate reeducation with the operator and the company's own employees. During the reeducation, the near miss or accident is analyzed. 
Though the company documents individual operators who are unqualified, the real assessment is of the company providing the crane and operator. If a given rental company sends an unqualified operator, it seriously damages that rental company's ability to get the business again. When establishing a relationship with a new rental company, the company will start them off on smaller jobs. These smaller jobs are generally less hazardous and are less in the public eye. Large construction projects in highly trafficked areas are places where accidents can severely hurt the company's brand and consumer goodwill. 
Most mistakes by rental company operators result from an inability to understand and respond to signals. The company representative liked the signalman portion of the standard. When the signals aren't being understood correctly, it's the company's employees near the crane who are in the most danger. Issues with ground conditions and power lines come up less frequently. It's generally the general contractor's responsibility to do something about ground conditions. That, combined with the assistance of the crane supervisor, helps prevent accidents caused by improper setup.
IV. Crane supervisors
When the company decides they need to rent a crane and operator for a particular job, a supervisor from the rental company will visit the site. That person is in charge of assessing the site and dispatching an appropriate operator and crane for any given situation. The representative believes that helps with the identification of hazards particular to a job site, since the supervisor will have already been on the scene to assess things like ground conditions and the proximity of power lines. This preliminary work helps ensure that the crane time the company is paying for is spent on the job itself. The assistance of the crane supervisor is included in the rental cost, and does not vary depending on how much of the supervisor's time they need.
V. Other thoughts
The representative has considered bare rental arrangements and training their own operators. However, he doesn't believe it would be possible to do that in a way that was both economical and safe. The rental companies have increased their prices by about 10%, purportedly because of compliance costs with Subpart CC. Prior to the standard coming out, the company didn't check for operator certification. They do now, however. Most operators are experienced; there aren't many new ones these days.
Interview #15- Large Construction Company

I. Introduction/Background

OSHA spoke with a representative from a large construction company that specializes in building custom water tanks, industrial tanks and vertical storage structures in addition to other occasional industrial and commercial construction projects.  Ninety percent of the crane work is hanging steel for the construction of tanks at a variety of sites, including power plants, refineries, coal mines, as well as for municipalities and private companies.  Construction crews can vary in size from five to fifty people, and work can require one or several cranes.

This company uses cranes in all, or nearly all, of its projects.  The operators are typically also the project foremen.  It owns some cranes (mainly rough terrain cranes, and one truck crane) that can lift up to 45 tons, and many of its employees are certified operators.  Everyone who operates cranes for this company is a certified crane operator.  It also bare rents cranes (usually larger or more specialized cranes) which its own employees will operate.  Finally, it brings in operators as subcontractors for larger cranes or specialized cranes on certain projects.  Usually the company will bare rent cranes up to 70 ton capacity and use its own operators, while for projects requiring cranes with capacities of 75 tons or more it will generally subcontract to a different company that will send a different operator to do the work.  Also, the company just has one main crane yard, so when it is doing a job in another part of the country, sometimes it is more cost effective to bare rent a crane similar to one that the company owns, rather than moving the crane cross-country.  When the company does bare rent a crane in these situations, it will try to rent one that is most like the model of crane that it already owns, since the operators are familiar with that kind of crane.

II. Training new operators

This employer rarely hires a new operator.  The operators for this company are much more than just ordinary operators  -  they are also welders with a very specialized skill set -- "Tankeys."  Some weeks, there will be lots of crane work, but other weeks, the foremen who are certified operators may just be doing welding tasks.  The representative said sometimes the employer has decided to employ a few higher-capacity operators or operators with skills operating conventional cranes.  However, in general, operators are laborers who have moved up in the ranks of the company after years of service.

The kind of construction this business does requires a lot of welding.  The employer rarely hires union workers.  The employer will employ laborers with welding skills, and they can work their way up into higher jobs.  Because crane operators are typically also foremen on this employer's job site, leadership or management skills are qualifications that the company looks for in deciding who to train on a crane.  The laborers work around cranes every day and learn what the crane does as they develop tank building skills.  When a foreman or other management personnel in the business begins to think that one laborer exhibits skills (such as welding skills, leadership skills, confidence, competence, etc.) that might make him or her a good foreman, the foreman that works with this laborer might let that person know.  That person will start thinking about the crane work differently, thinking "that could be me in the crane" and pay attention to the work that the foreman/crane operator is doing.  

Eventually, the foreman will start familiarizing the potential future foreman/operator with the crane, how it works, and start allowing the employee to get some crane operating experience like its maintenance/inspections, setting it up, rigging, its controls, its hazards, teaching that person to operate it.  There is not a formal process for training these potential operators/foremen; rather, the training is integrated into the day-to-day work.  In addition, the company currently employs 7 people in its safety department.  These loss control committee members will have an opportunity to assess the skills and potential of this employee because they are frequently conducting audits and may see that individual perform work.  Once the foreman or a loss control committee person identifies that this employee may be ready to become a certified operator, the employer will talk to the other foremen who have worked with this individual to get feedback as well.  Then if appropriate, the employer will send that individual to an accredited testing organization to get certified as a crane operator.

It is not uncommon for the employer to offer the opportunity to an employee to begin learning to use a crane only to determine that this is not something that employee is good at--the employee is better suited as a welder.  Also, some employees get weeded out at the certification phase.  Some foremen do not have the hand-eye coordination to be a good operator, so some employees make foreman without being an operator, but in general, the foremen are the crane operators on most job sites.

Once the individual is certified, he will be allowed to do more difficult supervised work using the company's cranes.  He will then slowly move into unsupervised lighter-duty work, followed by harder assignments.  This would be at the same time as this individual was advancing in other skills/moving toward assistant foreman or foreman.  The length of the entire process depends on the individual's ability, but could a year to multiple years to complete.

III. Operator Certification

This individual believed that OSHA should not extend the enforcement date for the operator certification requirements, because he believes that this requirement makes the crane industry safer.  OSHA explained that it is in the process of gathering information from employers to better understand what it takes to qualify crane operators and what employers of various trades and business models do to ensure that qualified operators are operating cranes.

This employer sends potential new operators to get certified toward the end, rather than the beginning of their crane operator training.  The employer does not want to invest in certification on the front end until the employer confirms that the operator has sufficient skills and knowledge to run the crane safely and will be a good fit both as an operator and foreman or leader on the worksite.

This representative felt that the certification organization that it works through provides a very difficult to pass test and that it gives you a base beyond what on the job training provides, such as expertise in load charts.  The company representative stated that the accredited testing organization that it uses administers a test that is difficult to pass if an operator cannot read load charts, does not know the basic controls of a typical crane, does not know applicable federal state and local requirements, and cannot recognize hazards associated with a crane. Even though it validates mostly "book knowledge," the certification is much more than a "learner's permit."  If a person does not have a concept of cranes, that person is not going to pass the operator certification test.  Also, some individuals may seem like they have great potential in the yard or on the job site, but then once they are under the pressure of the certification test, they bomb the test, so the test is good for weeding people out in that way as well.  

Certification does not necessarily impact this business's insurance rates; however many of the companies they work for will require operator certification and request the operator certification cards.

The company attended the Cranes and Derricks Negotiated Rulemaking Committee (C-DAC) meetings and presented at the informal public hearing, and submitted public comments. When C-DAC reached consensus on draft regulatory text that required testing by accredited 3rd-party or audited employer certification programs of operators, the company was totally against that model because most employers could not afford to get accredited. The employers were basically not allowed to qualify their own operators anymore. However, over the years, the company has seen and experienced the benefits of 3rd party certification. The company representative explained that removing certification would be detrimental because a lot of companies will try to skirt qualification requirements unless it is something formal like this.  This kind of requirement weeds out bad operators; eliminating it will set the construction industry back.  The representative believes that many in-house certification programs are not sufficient to ensure safety.  The representative knew of particular cases where third party certification greatly reduced the number of operators a company had, and implied that certification had weeded out unqualified operators.

This representative felt like employers' role in qualification is important, but did not believe that it should necessarily be part of the rule because it might be something compliance officers just cite when there are no obvious violations.

At first this representative did not support operator certification, but since the creation of Subpart CC and the expansion of operator certification, now he has seen how valuable it is to ensuring safe operators.

IV. Moving Crane operators between types and capacities of cranes

Employees are not limited to operating just one crane.  Sometimes they will operate a rental crane that is similar to the employer-owned cranes, and sometimes they will operate an employer-owned crane.  A lot of crane operation is muscle memory.  In this kind of construction, employees learn to do a set job  -  they may build different sizes or models of tanks, but they are not switching the types of lifts, rigging equipment or materials, so the skills are transferable between cranes.  

The operators generally get certified to operate small and eventually medium-size cranes.  They may move between cranes  -  a job can't necessarily stop just because a crane breaks down, but the operators usually stick to one "class" (similar type/capacity) of crane.  Although the different makes of cranes have different computer operating systems, they are not made to be too difficult to understand; so in this employer's experience, employees are able to move between them.  The manufacturers try to make them user friendly/know who their audience is.  When the employer rents a crane, it doesn't show up until rental day, so although an operator will practice some without a load before using a rental on the job, the operator can't practice all day since it is only going to be used temporarily.  

When the employer decides someone needs to be able to operate a large crane for an upcoming job, the employer will send that employee to get certified for a larger crane.  For really large (over 75 ton) or specialized cranes, the employer will either hire an operator that has specialized skills and experience or bring someone in as a subcontractor.  

V. Hiring experienced crane operators

Occasionally, the employer will hire experienced crane operators who have a background in higher capacity, specialized, or conventional (rather than more modern, joystick controlled) cranes.  This is the exception, rather than the rule.  The employer would require someone with operator certification and look at that person's history and qualification for someone with field experience in welding or something related if possible.  The employer would not typically hire someone with a background in hydraulic cranes but no welding or other relevant tank-related experience.  

Once hired, the employer would start a new employee on an easier job to see how they work before letting them do something more dangerous/high profile.  Also, the employer frequently conducts safety inspections and the employees are all used to working around cranes, with many certified operators and also more than one certified operator on some jobs sites.  This provides checks against a risk of hiring someone without adequate experience.  The employees know if an operator does not know what he or she is doing from working with cranes every day.  Also, ability to signal properly ("Tankeys" have specialized "Rap" signals) would be an important criterion, and would provide a good indication if someone was not a qualified operator for this kind of work.

VI. Rental Crane operators/subcontractors

When the employer brings in subcontractors to perform crane work, a rental crane company is typically just going to provide a certification card as proof of an operator's skill set.  The rental company will typically not provide any other information, such as what jobs the operator has completed recently or how much experience the operator has.  You can tell if an operator shows up to perform a job and can't do it properly, however.  Most of the crews are going to have at least one certified operator.  In addition, most of the laborers will be able to tell if the subcontracted or rented operator can't hang steel right  -  the guys are used to receiving it and they are aware if it is jerky or too fast, and won't take risks.  Foremen will notify the higher level management and they will pull subcontractors/rental crane operators off of jobs.  This decision would be made above the foreman.

VII. Continuing to ensure that operators are trained/qualified

The company conducts more than 100 safety audits of its job sites every year, so people are always being watched to make sure that they are really qualified.  In addition, under certification, operators must get re-certified every five years.
Interview #16- Medium to Large Home Builder

I. Introduction and Background

OSHA staff hosted a call with a medium to large homebuilder in the Midwest US.  Like many homebuilding companies, the company started out renting cranes and those rental companies' operators as needed on residential and light commercial projects. Eventually, the company had enough work that it was more cost effective to buy a crane and keep that work in-house. The company's representative is now retired, but his company consisted of 275 union carpenters, owned and operated three 32-ton hydraulic boom truck cranes, and maintained three operators on staff to run them. Had the company remained in business, the representative said he would have bought three more cranes to support his operation. In general, each of the employer's crane operators operated the same crane all the time.

The company's cranes and operators were also occasionally subcontracted to other homebuilders as available work demanded (they would never bare rent their cranes). Similarly, the company built homes and small office buildings contracting for cranes and operators, such as when projects required more cranes than those the company owned, or when multiple projects requiring cranes were ongoing at the same time. For jobs that required higher capacity cranes (up to 100-tons or so), primarily for their longer reach, the company rented a crane and its union operator or subcontracted another company to run the cranes they owned and operated.  The employer worked frequently with a large Midwestern crane operator rental company, as well as some small independent contractors.

Cranes were typically used on homebuilding sites for a minimum of two hours, but could be used up to eight hours normally. The cranes were used to hoist loads of building materials and structural members that typically weighed 200 lbs. or less. The hoisting jobs were performed in support of setting steel I beams in basements, staging floor joist and cold-formed steel framing, handling exterior and interior wall panels, staging upper level floor joists, and handling roof trusses.

Occasionally, the company was subcontracted to assist tree-removal and utility contractors after bad storms. When working next to power lines, his company implemented more protective work practices, such as requiring the use of spotters and signalmen. However, the power lines are typically underground in that region of the country.

II. Where the Company Got Its Operators

The company's crane operators were hired under a variety of circumstances. The first operator was a union carpenter who worked for the company for many years before deciding that he wanted to become the company's crane operator. A second operator was hired who obtained his prior experience operating a crane while in the military. The third and fourth operators hired were already union operators.

III. Role of the Union in Qualifying Operators

The company hires and works with primarily union operators because of the training and operating experience that they already receive from the union. Everyone knows who the bad operators are because of the local nature of the market, where employees and operators typically work the same jobs and for common employers over the years. The representative stated that the union training in this particular region is excellent. The company is more interested in finding safe operators than finding operators based on their qualifications. When they are needed to handle incoming loads, union carpenters only want to work with operators who they know will not knock them off of elevated work positions like upper floors, top plates, and roofs, and in general operate safely. Therefore, word gets around quickly even among the union carpenters regarding who the bad crane operators are. 

IV. Operator Evaluation Process

Operator 1:

The first operator was a union carpenter that worked for the company for many years before deciding that he wanted to become the company's crane operator. When the company bought its first crane (a 32-ton Manitowoc), the employee's operating competency was ensured through the following process:

   * Step 1- Basic Knowledge of the Crane
      
      The company paid the crane manufacturer (Manitowoc) to spend several (5-6) days teaching the operator candidate all about the crane. Topics covered included the crane's controls system, load charts, maintenance procedures, configurations, stability, set-up, inspections, and applicable federal, state, and local regulations.

   * Step 2- Familiarization with the Controls
      
      The operator candidate was allowed to practice booming in and out, setting the outriggers, and generally operating the crane for a couple of days to the point that he was familiar with the controls and could control the boom and load line. 

   * Step 3- Mentoring
      The operator then became a member of the local union operators and spent two weeks performing limited hoisting operations under the supervision of an experienced union operator.

   * Step 4- Monitoring

      The operator was assigned hoisting tasks at jobsites and feedback about the operator's performance on those jobs was frequently received from owner, other experienced operators running cranes on the jobs, and various hoisting crew supervisors and members.

   * Step 5- Career Development

      The operator continued periodic training provided by the union. When the company bought two more cranes, the operator was allowed to train and improve his operating proficiency on those cranes. When the operator was moved to another type of crane (National), the employer sent the operator to get additional training on that type of crane. The operator became the senior crane operator for the company and participated in the mentoring of the other crane operators as well.

Operator 2:

Their second operator obtained his prior experience operating a crane for ten years while in the military. The second  operator then trained on the original crane (Manitowoc). The company basically used the same steps to ensure the operating competency of this new operator as well, except he did not receive training from the manufacturer as the first operator; nor did he spend two weeks operating the crane under the supervision of a union operator. Even though the new operator was certified by the military to operate a similar crane, it took him a while to get proficient at: setting up the crane on often congested, newly constructed, residential worksites; and performing the types of lifts and in the manner necessary for the performance of homebuilding work. He worked for the company for a couple of years, but never quite got accustomed to performing residential construction work and found work elsewhere.

Operators 3 and 4:

The company bought a third crane (Manitowoc) that was of the same type and capacity as the first two. The two senior operators were assigned to operate specific cranes to perform hoisting jobs in support of residential construction work. The operating competency of the 3[rd] and 4[th] operators hired was ensured by using the same process.  After the second operator left, these operators were trained and qualified to each operate one of the 2[nd] and 3[rd] cranes bought by the company.

V.  Role of the Company in Dealing with Bad Operators

The company representative explained that union carpenters in their region of the country are all trained riggers and signal persons. Therefore, they are the first line of defense in identifying operators with bad work practices such as not following instructions, swinging loads too fast, or otherwise endangering other employees on worksites. The company's foremen are usually the people of authority who can stop operations when they appear to be unsafe.  They can call the office and have a particular operator removed from a site. When the operator is an owner/operator, calling the office may be necessary for contractual reasons to have an operator removed.

When the company needed subcontractors to perform crane work, it usually worked with the same large crane operator company that hired union operators, and occasionally with some independent contractors who owned cranes. In almost all cases these were union operators so the representative felt confident that they would be well trained.  It was not that uncommon that an experienced crane operator would go out and buy a crane and start their own small independent company. Normally such an owner-operator would get certified to have the certificate to show to prospective employers. Additionally, they would only work with other companies with a good reputation in the crane community. The representative would ask his employees about unknown new operator companies that tried to solicit business from him before working with them. If a crane operator is a bad operator in this industry, people in this community will find out and talk about it and that person will not stay in business long.

VII. Certification verses Qualification

The company's representative believes that qualification of operators is much more important than certification. Certification does not include the crane-specific, hands-on experience needed to operate a crane safely. Often certification organizations use simulators to evaluate the skills of an operator and even after passing those tests, they still do not have enough experience to operate a crane at a job site. Residential jobs can be even more challenging to crane operators because they are performed on previously disturbed soil that has not been tested by soil experts or that may have unknown voids beneath it, unlike most commercial projects in cities which are more likely to be surveyed by engineers. At other times, commercial projects require more blind lifts, use of signal persons, and the hoisting of heavier loads that require experience that an operator may not get on residential jobs.  Operator qualification must be crane-specific and job-specific. Therefore, the company's representative believes that residential construction should have a separate set of requirements that are specific to the hoisting jobs done and equipment used. 

Residential construction is often variable in the amount of work available, which gives an incentive for operators to keep up their certification to give them a better chance to get hired in down times. The company's representative stated that supervisors on residential jobs often do not know enough about cranes to have the skills to assess a crane operator's abilities to operate a crane safely. Therefore, a controlling employer's authority is crucial to ensuring safety on the worksite. The company's representative also believed some of the training in crane certification could be inapplicable to or superfluous to the training for residential work.  He then emphasized the differences in operating different makes of crane (National versus Manitowoc) and made a point of getting training for each operator specific to each machine that individual operated. He felt that an operator experienced on a larger crane (say, 100 ton) would have an advantage in moving to a lower capacity crane (say, 30 ton); moving up in capacity would be more difficult.

The one crane incident that the company experienced was caused by an outrigger pad breaking, which caused the outrigger to begin sinking. The company's operator was skilled enough to quickly recognize what happened, safely set the load, and position the crane such that it did not tip over. That incident confirmed that all of the time and money invested by the company in that operator's training was well worth it.
Interview #17- Safety Training Company

I. Introduction
OSHA spoke with a representative from a construction safety training company located in the western United States. The company trains personnel in workplace safety, including riggers and signalpersons, and performs safety consulting which entails performing worksite safety evaluations on behalf of construction companies, typically general contractors. Note that they do not qualify crane operators. Operator qualification has come up, however, when the company inspects worksites for safety issues.
II. Unqualified operators
In general, most crane operators are qualified and do a good job. However, the company has evaluated worksites that had operators not qualified to operate cranes. The best way to tell if the operator isn't qualified is by evaluating the condition of the crane. Frayed wire rope can be a good indication that the operator was not conducting the required inspections. If the crane looks like it isn't in good repair, the company will generally follow up by interviewing the operator. The company will ask the operator about his or her experience level and certification to perform the task. Operators with a certification card are generally better educated on crane safety.
The bigger construction outfits have the larger equipment, such as tower cranes, and are more frequently certified and qualified. Typically, the unqualified operators are owner operated subcontractors with a single, small crane. It is not uncommon to see these at residential construction sites. Particularly, when production is up, contractors may choose to work with crane operator subcontractors that are less qualified because more qualified operators are all booked. Sometimes, the general contractor wasn't competent to evaluate the skills of the operator and/or had not used that particular subcontractor previously. General contractors typically ask for certification from subcontractors, but sometimes they don't evaluate every subcontractor that comes onto the site. 
For smaller companies, just getting the certification is a tall order; to require a more robust in-house training and qualification program would likely be more difficult.  This company representative found that more operators currently are certified in Texas than Colorado, and many small business operators are not certified and do not understand what the new OSHA regulations are about, especially in Colorado.  However, this representative is happy to see more of a focus on certification going forward.
When mistakes are made on the jobsite, they're generally because the operator makes a mistake operating the crane that is unrelated to the hazards particular to that jobsite. Most errors are setup errors, such as the outriggers not being out. Other common errors involve poor rigging or overloading the capacity of the equipment. A problem with safety in the homebuilding industry is a "get the job done attitude" which leads to rushing with rigging decisions. The company trains employees how to communicate with the operator, and to recognize and react to any errors. Most of the people the company trains as riggers or signal persons are primarily engaged in other trades, and only occasionally need to work with a crane.
Interview #18- Large National Construction Firm

I. Background

OSHA met with a large national construction firm that owns nearly 1,000 cranes of all different types, and does a large amount of highway and mine construction.  Of the nearly 1,000 cranes, 230 are mechanic's truck cranes that do not require certified operators, but the company owns tower cranes, hydraulic cranes, crawler cranes (230 cranes are rough terrain), boom trucks (66), and even cranes that are barge-mounted.  Typical large projects include building bridges and dams, but the company is diversified, and does a lot of different kinds of work, with projects that require one or no cranes up to projects requiring many cranes.  The firm is increasingly doing more construction related to oil, gas and power plants.  At any given time, the firm will have 300-400 projects, with roughly 15% being large projects.  The firm has more than 30 some operating groups throughout the US and Canada, and a small presence abroad.

The company employs around 1,200-1,300 crane operators, and has both union and non-union crane operators.  The company typically hires experienced crane operators.  In the northeastern operating groups, these are usually union operators, whereas in the south, they are usually non-union.  The company will typically hire operators for a specific job, but jobs can last for years.

Each operating group has a crane compliance manager, but these employees also often wear multiple hats, such as Department of Transportation compliance officer (manager) and crane compliance officer (manager), as well as safety manager.  

The firm most often acts as the general contractor for projects, but it does occasionally serve as a minor partner on JV work. The company is the general contractor approximately 90% of the time but does as much of the work as possible. It is also often involved in joint ventures, more often as the lead partner (more than 50% of the project) than the minor partner.  When the firm (company) is the lead partner, both partners follow this firm's policies.  The firm also prefers to use its own cranes when possible. The firm does not ever rent its cranes outside of the firm or lease cranes to other contractors.

II. Crane Operator Certification

The company generally supports crane operator certification because it raises the bar for crane operators across the country, but this employer has a higher standard of experience and performance for operators of its cranes.  The company recognizes that there are important distinctions between type, capacity, and also configuration and manufacturer of cranes.  The representative believes that ground conditions and set up, as well as load moment indicators (LMI), are important parts of qualification knowledge.  However, seeing that an operator has a card does at least give the employer an indication that the employee has some background with cranes.  This employer representative would not let an operator run a crane based on the certification alone, but would fully verify the employee's credentials, as discussed subsequently.  In addition, this employer believes the employer should still have a burden to ensure operator qualification in addition to the current certification requirement.

When the firm learned of the certification mandate, it set a goal of achieving 100% operator certification by 2012.  When the firm hires new operators, and they do not have a certification they have a six month grace period to become a certified operator.

III. Qualifying Experienced Operators 

This firm has a comprehensive process for hiring new operators to evaluate whether they are qualified and ensures that they meet OSHA criteria and satisfy company policy.  For crane operators that fall under "regulated cranes"  -  boom trucks, truck cranes, barge cranes, etc., this process is the Authorized Operator Program.  For mechanic's trucks cranes, forklifts, scissor lifts, etc., they don't fall under OSHA's cranes rule, so they are covered by the Designated Operator Program.

Authorized Operator Program:   Each candidate crane operator undergoes, individually, a day and a half long evaluation and testing program.  The firm relies on the authorized evaluator in each operating group to determine if a prospective candidate, who must have prior crane experience, is qualified to operate their cranes.  Prospective new hires may be union and nonunion who have prior crane operating experience.  When the firm needs a crane operator, HR finds a candidate operator.  HR will make sure the operator meets the firm's drug test requirement and has a current physical (either NCCCO or DOT is accepted).  80-85% will already have crane certification cards, and union employees have already at a minimum been through the apprenticeship program.  The certification card is not sufficient to make a candidate qualified.  Certification tests do not include set up operations, driving cranes, rigging, nor reflect operating cranes with actual loads at a construction site.  

The firm follows a corporation-wide crane procedures manual which sets the firm's policies.  These policies are based on regulations and standards as well as past experience and lessons learned from accidents [incidents] and near misses.  

This employer does not train its operators, but seeks operators who are already experienced.  Their program allows the firm to verify operators' abilities as well as make sure they understand company expectations. In essence, the company is not in the business to train operators but they do a thorough assessment of experienced operators' skills. The company does acknowledge that oilers, or crane assistants, acquire crane and construction experience and that these individuals are introduced to crane controls and may practice operating the crane as part of their jobs.  But their model of ensuring that crane operators are qualified focuses on the evaluation of experienced crane operators by the authorized operators, not training and mentoring.  Occasionally they will hire an operator who needs practice or development in one or two areas.  The site superintendent where these crane operators work are notified of a deficiency and work with the new operator to improve performance.  

Authorized Examiners: The Authorized Operator Program is given to prospective experienced operators by the authorized examiners.  This firm has "hand-picked" very experienced personnel (most likely managers) to train to become authorized examiners, who are then able to determine someone's qualifications to be an operator for specific types/capacities/manufacturers of equipment and also for different attachments.  The company provides extensive training for its authorized examiners.  Of more than 200 that were handpicked to become authorized examiners, so far about 127 have completed the training and development program, and some have not finished all the qualifications.  Ultimately, the firm hopes to have 75% of that group become authorized examiners.  The process includes completing several of the written exams of the NCCCO crane certification, 5 years of experience in the industry, a thorough knowledge of the company policy manual, a 2 day training on the manual, a thorough knowledge of safety standards including OSHA and ASME, and the Crosby 20-hour rigging course. Most of the authorized examiners will also have crane seat time, though this is not a mandatory requirement.

Many jobs with multiple cranes will have onsite crane managers.

The authorized examiners go to each different job site where a new operator is hired and run the operators through the authorized operator program.

The Authorization Process:  Prospective operators with lots of experience will not be "belittled" by the process and some steps can be "grandfathered" in, but all operators' skills will be evaluated.  People who complete the Authorized Operator Program are issued cards from the firm that specify what they are authorized to operate (manufacturer, type, capacity, and special configurations). This card will be good for five years and will be evidence for the employer.  Cards identify which cranes an operator can work by manufacturer because the controls can be different, as can the load moment indicator.  About 8-10% of new hires don't make it through the authorization process.

The authorized examiner verifies knowledge, testing, knowledge of the crane operator manual and the firm's policy manual and verifies practical skills as well.  First, the authorized examiner will give the incoming operator a basic test, maybe 25 questions, and if that person cannot pass the basic test, then that operator might be rejected from the job.  Then the potential new hire will complete three e-learning modules, the first on nomenclature and basic safety, the second on crane safety and policies, and the third on the company's on the spot lift plan requirements.  Really experienced hires may get to skip the first module at the discretion of the authorized examiner.  

After this, the new hire must read Section 1 of the firm's policy manual and take a written test on that.  Again, if the authorized examiner feels like the operator does not have the skill necessary to operate a crane after this second test, this individual can be dismissed, but already some time is invested so the firm recognizes that some individuals may be great in the seat and just bad at taking tests.  If the operator doesn't understand something, the authorized examiner will help the operator to understand the policies. 

Next, the candidate operator will review the operator's manual(s) for the crane or cranes that he will operate and take a 15 question assessment where the new hire must find the information requested in the manual to familiarize himself with the manual format.  Manuals can be very large  -  six volumes or more.  Then the new hire will perform a similar assessment in review of the full employer's policy manual.  Finally, the new hire and the authorized examiner will cover any additional job-specific or site specific issues (underground utilities, power lines, ground conditions), relevant required OSHA training, owner-specific site rules.  A discussion is also conducted that covers information about specialty jobs (duty cycle, luffing jobs, floating equipment, auxiliary counterweights), if applicable.

On day two, the authorized examiner will do the practical assessment.  First, the examiner and the operator will walk around the crane at the job site, and the examiner will teach the operator about the firm's daily visual inspection sheet and how to fill it out.  This form is specific to type of crane.  The authorized examiner will ascertain the operator's knowledge of signals, rigging, shackle orientation, sling angles, crane travel limitations, load charts, LMI set up, and practical skills.  The operator will be observed while he or she (1) makes sure crane is set up properly and level, (2) reads the load chart, (3) programs the LMI, (4) completes an on the spot lift plan, (5) picks an item up 12 inches off ground  and moves it from one place to another-.  This includes testing on proper rigging, signaling, and following the lift plan from A to B.  Although the load might not be typical of the work to be performed, the equipment will be the same or similar equipment to the equipment the operator is expected to operate to perform work for this employer.  This practical test will be about 4 hours.

For specialty configurations, such as luffing jib, pile driving, duty cycle, or foundation work, there will also be another specialty exam and another training portion, including practical testing on the specialty application.  Changing the configuration of the crane can change how the crane should be operated.   

After the authorized examiner is satisfied, the next challenge is handing off the operator to the job superintendent.  The examiner will issue the operator a temporary card, and will also give the operator, as well as the superintendent feedback on any areas where the operator is weak or any restrictions on crane use.  The superintendent will be asked to monitor the new operator going forward (for example if the operator is weak at rigging, the superintendent will keep an eye out to make sure that the operator doesn't make rigging mistakes, and review rigging skills as the operator moves forward with the job).  The firm will make the permanent card that will identify what cranes the operator is qualified to operate.  The authorized examiner will also give his contact info to the operator to be a point of contact in case of difficult safety situations going forward.  However, the responsibility for the newly hired operator is now transferred to the job superintendent.  The recently hired operator will start out with somewhat easier tasks and will be closely watched at first.

In summary:

HR Finds Experienced Operator
Authorized Examination
      a.Classroom
      b. On-site Practical
Hand Off To Site Superintendent
If necessary, mentoring and OJT based on Authorized Examination's recommendations
Periodic Observation by Authorized Examiner 

IV. Qualifying New Operators

The firm usually hires experienced operators, but occasionally operators will work their way up from a forklift or other light equipment operator to a crane oiler and gradually learn crane skills.  To become an authorized operator, that individual will go through the same evaluation and testing process described above.  The process from oiler to operator could be anywhere from 6-8 months to a few years.

V. Auditing the Program/Workplace Safety

The firm has two different safety auditing programs.  First there is an internal auditing group without specialized crane knowledge.  They have been trained in recognizing some crane hazards, and what the regulations are.  They audit the "Top 5" risks on each work site  -  a certain amount of audits per month  -  and cranes is almost always a top 5 risk.

Second, there is a team that is a "operating group" of its own that audits crane operations and operators.  Each of the four regional crane managers conducts one audit per month, so 48 are done per year.  These are more in depth reviews of the crane operations, policy compliance, rigging and signaling practices as well as the operator's abilities.  Following the assessment there is a pass or fail and if there is a fail, the job site is given three weeks to resolve problems and then there is a follow up assessment.

The different crane compliance managers in each operating group keep records of the qualifications of each operator but there is not a centralized system yet.  The company is moving toward a website with all operators in one database.  However, the firm-issued crane operator cards are transferable from one firm site to another.  The firm has 16 different classifications (comparatively, there are around 8 at NCCCO).

Because the firm's cards only last 5 years, there is a re-exam at the end of the five years before a card is reissued just to make sure an operator still is up to speed.  This review includes reviewing incident records and recent industry accidents.  This does not involve total retesting of the operators knowledge but, does require some review of the company's policy enhancements.

The firm has a strict accident reporting policy and keeps formal incident records, investigating all incidents, including near misses.  Accidents must be reported within 24 hours.  The investigation will determine the cause of the incident and then the firm will correct the issue with training, policies, or both.  The leading causes in accidents are operations, operator error and not following procedure.  The firm began tracking incidents in 2009. 

VI. Other Issues

Do site superintendents usually marry people to cranes?  Depends  -  policy changes under new cranes rule has changed the old policy of moving operators as often between cranes.  Also, union rules can have an effect.

Is the firm self-insured? Yes, up to a $250,000 deductible.  Anything higher involves a third-party insurer.

Who performs maintenance?  The firm does most of its own maintenance.  It runs a tight ship with maintenance and relies on the original equipment manufacturer.  There is a manufacturer repair/rebuild facility in Wyoming to refurbish cranes for a second life.  When the employer does a modification, it gets permission from the manufacturer on letterhead.  The manufacturer also does some repairs.

What does the firm do when it rents a crane/operator?  Typically, it will rent from local crane rental houses of which it has prior knowledge and/or will put them through a vetting process.  The firm will rely on the rental operator's employer to vet that person's experience but will request to see a certification card, and make sure that the operator understands company expectations/policy.  The risk is still the rental firm's, and this firm is not going to "authorize" rental crane operators.  Likewise, the company does not assess and qualify another employer's operators.  If a subcontractor's crane operator is found to be inadequate, the employer as the general, or controlling, contractor will step in have them leave the site.  The company understands its responsibility for safety includes requiring its own employees and subcontractors to work safely.  Subcontractors are contractually required to follow the safety procedures in the company's policy manual.
Interview #19- Regional Propane Tank Distributor

I. Background
OSHA conducted a site visit at a propane distributor.  Representatives from a propane industry trade association also were present for the meeting. The propane company operates several facilities primarily in the eastern region of the U.S. This site visit was conducted to gain a better understanding of this company's propane tank delivery process and the skills necessary to operate hoisting equipment. The company provides propane-related services and uses cranes primarily to deliver propane tanks to clients. However, the cranes are also are used to deliver tanks to construction sites such as buildings in latter phases of the construction process. Crane operator certification requirements were also discussed at this meeting.  
The company operates approximately 50 delivery centers in 11 states and maintains a fleet of 49 truck cranes in addition to many service and propane-supply trucks. The delivery of propane tanks and servicing operations are predictable and for the most part routine; so there is no need to rent other types or capacities of cranes as workload might dictate for more typical construction activities. Some company locations are small and may only have one truck crane. The majority of the cranes operated are boom truck cranes of 5,000-6,000 lbs. capacity. The company also has one articulating knuckle-boom crane to lift larger tanks or for their variable reach capabilities, but these are far less common in the propane industry than the boom truck cranes.  
II. Demonstration of Propane Tank Delivery
The company conducted a demonstration of a typical propane tank delivery first using an articulating knuckle-boom truck crane for a larger tank and then a boom truck for a smaller tank. The articulating knuckle-boom truck crane was configured with a hook that was attached to the end of the boom while the boon truck was configured with a typical load line hoisting system. Before operating the hoist, the service technician (crane operator) set the truck's stabilizers from an operating position right beside the stabilizers. The service technician hoisted the tanks from the truck bed, demonstrating how the booms of the two types of truck cranes work, and set the tanks on the ground. During the second demonstration, the service technician operated the boom remotely and simulated a lift during which the foundation pads had to be adjusted due to the truck's position (insufficient boom length) at a crowded worksite. The service technician also demonstrated his skills at troubleshooting a sticky anti two-blocking device that temporarily prevented the boom from being lowered during the demonstration. 
III. Training and Qualification
Service Technicians
The company hires primarily experienced service technicians who not only perform propane system services (such as diagnosing problems with inoperative appliances) for its customers but also operate cranes occasionally during the performance of their work. Propane is highly flammable and hazardous and trucks transporting it are regulated by the Department of Transportation. For this reason, the company prefers to hire technicians with five years of experience in the propane industry. In some regions of the country, service technicians are often "Red Seal" union-trained after completing a six-year apprenticeship program. On occasion, less experienced employees may be hired by the company. However, they are typically assigned to jobs in the storage yard or company buildings performing painting, maintenance, inventory, etc. until they become more experienced through training and eventually performing closely supervised technicians jobs. 
Due to the high-hazard nature of handling and transporting propane, to become a skilled propane service technician, an employee must be well trained and provided years of on-the-job experience before being allowed to perform most types of work unsupervised.  Because crane operation is just one of many skills a technician can have, the company does not currently employ certified operators.  Rather, they first provide their technicians with training materials developed by the Propane Education and Research Council. This is approximately three hours of initial training that consists of employees viewing videos of safety practices, taking quizzes, and participating in more advanced discussions of state/local regulations and company policies and procedures. Over several years, the company trains its employees to meet the qualifications of between 15 to 20 trade specialties, but very few are qualified in all subjects. The safety director described their industry as being somewhat unique in that employees often make careers within the industry as they master trade specialties and those with the drive to do more eventually become the managers of local propane companies. Therefore the managers typically have first-hand knowledge of propane operations from top to bottom. In light of the other hazardous jobs they do, in the opinion of the safety director, learning how to use the crane safely is one of the easier components of training for propane service technicians. 
Crane Operators
Likewise, as technicians master trade specialties, those that have ambition to do more are the most likely candidates to be selected by company managers to operate truck cranes and make deliveries. Most technicians gain operating experience through the performance of routine maintenance and crane set-up necessary for tank handling jobs in storage yards. These employees often accompany more experienced operators on deliveries to learn how it is done under typical worksite conditions encountered at delivery sites. The duration of ride-along and supervised job training period varies based on the individual technician's capabilities.   
A technician is considered a crane operator only after demonstrating his or her operating proficiency through on-the-job-training and meeting various other qualifications, such as those required by the Department of Transportation for truck drivers and the handling of hazardous materials. The company intends to get its operators certified by November of 2014, or November of 2017 as the regulation date of compliance is expected to change, to comply with federal law because they will continue to deliver propane tanks to construction sites. A representative from the trade association estimated that around 10 percent of new construction jobs (such as new homes in rural areas) annually will require propane delivery. The safety director commented that it is often easier to deliver tanks to new construction sites because of the abundance of space for crane set-up, and the lack of fences, road traffic, energized power lines, and issues with landscaping to deal with. 
After a technician has been qualified to do deliveries unsupervised, the operator is very likely to be assigned a specific crane or two that he or she must use to perform very limited  types of lifts involving only a couple of the industry's standard sizes of propane tanks. Lifts of very large tanks are subcontracted to employers who operate bigger cranes and has operators qualified to run them safely. 
IV. On-going Evaluation of Service Technicians
The company periodically performs evaluations of its operators' proficiency while doing deliveries and handling tanks in the storage yard. These evaluations generally occur at three-month intervals, but vary based on the operator's level of experience and proficiency. The company requires reporting of near miss incidents and consults with technicians about any abnormal conditions encountered at delivery sites.
The technology in cranes is always evolving that requires the company to ensure that its operators are trained to safely use new equipment with advanced features such as: newer computer systems/load moment indicators, wireless remote controls, swing-down truck bed gates, varied boom configurations and attachments, etc. The safety director was confident that, even absent operator certification regulations, propane delivery centers will always baby their newest cranes because they have so much invested in them. Therefore, only the company's most qualified operators will even be able to touch those particular cranes for years to come.
V. Concerns of the Company
On its face, the accredited certification process first seemed intimidating to the safety director. After doing a little research, he determined that the testing organizations only evaluate or test very basic knowledge of general crane operations. That knowledge has little applicability to the cranes that are used at the worksite or to the activities performed by propane service technicians. In addition to the training already provided by the company, the company does not believe that certification of its operators adds much to safety because crane operations are limited to propane tank handling and delivery. The company's safety director added that certification does not train (or test) crane operators to use cranes to perform specific propane service and delivery activities. He noted that certification testing also ignores important parts of their industry such as practical training for setting up the crane properly and machine specific troubleshooting.  
The company closed the meeting by explaining that training and qualification by the company has improved every year as they review and determine the causes of the incidents and near misses. The company is pleased that its service technicians have not experienced any injuries that were related to the operation of a crane, although they have sustained injuries that are related to the many other tasks that technicians perform. Because the company experiences so few injuries and have relatively low insurance rates, there is no need to self-insure as some crane owner/operators have done in recent years
Interview #20- Equipment Operator Training Company

I. Background
OSHA conducted a phone call with a representative from an equipment operator training company in the Southwest US. This call was conducted to gain a better understanding of this company's role in crane operator qualification and the elements of effective assessment of an operator's skills and knowledge.  The company employs trainers and assessors who have decades of operating experience.
The company provides 3-5 day training courses that are tailored to varying types and capacities of cranes and can be conducted at an employer's jobsite using the employer's cranes. Even though the training provided is often specific to the particular makes and models of cranes the operator will use on the job, the representative reiterated that the employer must still ensure that the operator gets additional training and experience in operating the cranes in configurations necessary to perform construction activities under conditions at the jobsite.
II. Trainers/Certifiers
The company hires experienced crane operators, often from an operators labor union.  The company then assesses and trains them regarding their skills to teach others how to run cranes. Again, these individuals often have decades of operating experiences to share with their students. In addition to experienced crane operators, there are others who may be good assessor of an operator's proficiency at the worksite.  Experienced riggers, maintenance personal, signal personnel, or tradesmen at the jobsite can quickly tell whether an operator is skilled at running the crane being used. Therefore, most companies know who the good crane operators are regionally.
III. Training
Operator Candidates
The company trains operators of varying degrees of experience and the courses are tailored to their level of experience and familiarity with particular types and capacities of cranes. In general, the representative described an effective way of training an operator as: using books, videos, simulators and other training materials to develop a basic knowledge of the crane, rigging, hand signals, load charts, etc.; hands-on operation, maintenance, and inspection of the crane; performance of supervised crane operation; evaluation by written and practical tests; and retraining as necessary for refreshers or to understand new technology or equipment.   
IV. Operator Assessment
Trained
The representative explained that written tests assess an operator's basic knowledge and only identify who should be considered for operation of the crane. The practical test assesses the operator's familiarity with the controls and ability to control the crane under set parameters. Depending on the type and capacity of the equipment, the practical exam may be waived when the operator has met experience requirements (1-3 years) specified by the training company. 
Certified
The training company prepares the operators for certification, but the representative stated that only a fool would rely on a certification alone as an assessment of an operator's ability to safely operate a crane at the worksite. The representative did believe that certification plays a vital role in the operator qualification process, but sufficient training and months to years of actual operating experience are needed to ensure the operator's competency.  The length of time it takes depends on the complexity of lifts and construction activities the operator is tasked to do at the worksite. The representative was convinced that, unfortunately, there is not a test or series of tests that could be administered to an operator that would cover all of the types, configurations, and capacities of cranes and the activities that they may be used to perform at the jobsite. Therefore, even when a certified operator shows up at the door for employment, the employer must verify that operator's skill level by designating an experienced assessor to make those determinations about the operator based on what is required by the job.
V. Concerns of the Company
The representative was concerned that a delay in the effective date of the certification requirements will compromise general crane safety. Once the certification requirements are delayed, employers that are not skilled at operator assessment will defer getting their operators certified, which means many will not send their operators to formal training courses that are designed to effectively identify their training needs and significantly supplement training provided by those employers. Just requiring operators to acquire certifications from accredited organizations alone will be more effective than leaving that assessment up to employers who don't have the skill to do so. The representative also added that in general, accredited testing organizations are good for the industry simply due to the processes that they have to complete to become accredited.  Due to the lengthy rulemaking process that OSHA must undergo to reexamine crane operator qualifications, the representative is afraid that the day when all operators will be verified through certification to have at least the same basic level of knowledge and skills will not come in the lifetime of those who originally drafted the rule. 

Interview #21- Large Construction/Crane Operator Training Company

I. Background
OSHA conducted a phone call with a representative from a large construction company that is based in the southwest US. The company performs major highway/bridge and other municipal construction projects as well as providing training for crane operators. For operator training purposes, the company employs trainers and assessors who have considerable equipment operating and training experience. 
The company provides 3-5 day training courses that are tailored to varying types and capacities of cranes and can conducted at an employer's jobsite using the employer's cranes. The company makes a considerable investment into these training programs in the form of the trainer's trip expenses, providing the students with training materials, the trainer's wages, certification testing costs, as well as costs incurred for hauling, donating, or renting a crane(s) for practical testing at remote sites.
II. Trainers/Certifiers
The company hires only very experienced crane operators, often from an operators labor union, and also assesses and trains them regarding their skills to teach others how to run cranes. These individuals not only provide training for the company's operators but are contracted by other companies to train their operators as well. Some train-the-trainer courses are provided as well. In addition, the company provides professional engineering services as well as always leaving the door open for former students and their employers to call on their crane expertise regarding worksite hazard assessments, the development of lift plans, and such. A representative added that, in general, the company has seen an increase in the quality of lift plans in their regions of operation and credits the certification of operators as a major contributing factor. Since OSHA published the 2010 effective date for certification requirements, both representatives have been pleased at how operators are now gaining the basic knowledge and experience to not only solve hoisting-related problems but to now predict and prevent them well before even attempting the lift. Through the company's training program, the operators also have learned how to better use their resources and where to go for help.
III. Training
Operator Candidates
The company trains operators with experience levels that range from beginner to having years of operating experience. A representative estimated that 90% of the candidates have considerable operating experience before enrolling in their training courses and do so to prepare for the broader subjects covered by the written tests administered by accredited 3[rd] party certifiers.  After taking the course, even with the average estimated 10-15 years of operating experience of their students, the company still estimates only a 60% pass rate for trainees who go on to take written certification exams. A representative added that some operators initially fail the written certification exam even though they are very skilled operators but just are not good test takers, have problems reading, or are not that good with math. The representative asserted that even those operators who do not pass the certification test come away from the company's training courses noticeably more knowledgeable about crane operation than before they took the course. Unfortunately some, more frequently the inexperienced operators, merely have been confirmed as most likely not having what it takes to be a crane operator and should not be in the cab of a crane unless closely supervised.
The company also trains an estimated 5-10% of what they call "greenhorns," those operators with very little operating experience. The training provided by the course gives these novice operators hands-on training with the cranes they will one day operate on the job. The training program also exposes them to the types of calculations, inspections, and hazard analysis that are typical for the safe operation of the crane at a typical worksite. One representative cautioned that it is not uncommon for even novice operators to acquire sufficient basic knowledge of the crane to pass the accredited 3[rd] party certification exams.  He even questioned the complexity and consistency of one or two of the certification programs existing in the industry now. Therefore, both representatives reiterated that just because a novice operator can pass a written and practical certification exam does not mean they can go out and, for example control a dragline or perform clamshell and bucket work at an active jobsite. They noted that these days, cranes are "more brittle," meaning that, unlike the older friction cranes that could take a beating, they must always be operated within their tolerances to prevent catastrophic structural and system failures. One representative  explained that operators, both beginners and experienced, must be taught to recognize the importance of using the newer cranes' operating systems, safety devices, and operational aids, to ensure that the cranes will be run within their tolerances.  Even more experienced operators may be tempted to try to do things with the cranes that the newer models are not designed to do.  
A representative voiced concerns about the rising number of rough terrain and boom truck cranes that can be easily bought and rented by employers to do a wide variety of construction activities and are being used more extensively to deliver materials to construction sites. The representatives warned that the skill needed to operate those types of cranes on a construction site is often grossly underestimated by operators and their employers. Subsequently, the representatives had many questions and reservations about what types of certification available today were most appropriate for operators of boom trucks.
Because of the many types, makes, and models of cranes available, and the wide variety of construction activities that operators are tasked to do, the representatives added that the employer still should provide additional training and assess the operator's skills based on what the operator will be tasked to do with the particular crane at the jobsite. Because the company provides supplemental training for mostly experienced operators, a representative also estimated that after taking their training course and passing the certification exams, up to about 90% of those operators could safely operate a crane at a typical construction worksite, such as for steel erection, residential construction, concrete work, etc. He emphasized that would be true based on the amount of seat time their students come to them with and not necessarily because they completed the company's training program. The company's training program assesses the operators' skill level and identifies his or her training needs. Both representatives are convinced that certification is a necessary and effective step in the process, but attempting to design certification tests that would qualify operators to run cranes at the site is "like shooting a moving target."  The training subject matter and certification has to be specific to the crane used and the crane work performed at the worksite.
IV. Operator Assessment
Certified
The training provided by the company prepares the operators for certification, but the representatives did not believe employers should rely on an operator's certification alone as a skills assessment tool. However, they noted that an operator running a crane without a certification is an obvious indicator that the employer did not verify minimal training obligations. Both representatives are confident that certification does play an essential role in the operator qualification process because, at a minimum, it is far more likely that employers who know very little about cranes will continue to have their operators assessed by those that do. A representative explained that because OSHA published a deadline by which all operators must be certified, it made many employers nervous and they reassessed how well they train their operators. Without that deadline, to save money, those employers will no longer have a regulatory push to ensure that their operators can at least pass certification exams; so they will just continue doing what they are doing. There are very good employers of crane operators and there some that need some help and the representatives believe that operator certification at least levels the playing field. The representatives are convinced that certification is still needed to keep the industry moving in the right direction with regard to crane operator qualifications.  
V. Concerns of the Company
The company views safety as an investment and a representative explained that safety directors, if a company is even big enough to have one, find it a challenge to convince executives that crane operator training needs to be upgraded or even supplemented by a more qualified 3[rd] party. Safety directors often use regulations, like the certification effective date, as leverage to convince their companies to expand training budgets to include more training and eventually certification of their crane operators.  Without a regulatory deadline for certification requirements, the representatives were concerned that more companies will now be reluctant to invest in the certification of their operators if w not required by OSHA. Under such scenarios, a delay in the effective date of the certification requirements will compromise general crane safety. 
The representatives explained that there are a many employers who subcontract all types of jobs and episodically rent cranes or buy used ones when the opportunity or need arises. Therefore, the representatives were convinced that, although not ideal, just requiring those employers to get their crane operators certified by accredited testing organizations alone will be more effective than leaving such an assessment up to short-term employers who are inexperienced with cranes and the skills needed for their operators. For this reason, the company reiterated that by OSHA requiring employers to get their operators certified, it ensures that all cranes will be run by only those operators who have at least a basic knowledge of the crane which is also essential. They were not confident that employers' training programs (especially really small employers or those that employ operators short term) ensured even that. 
In closing the representatives stated that when OSHA delays the effective date of certification requirements, many employers will breathe a sigh of relief because they will no longer have to raise the level of knowledge of their operators to that needed to pass the written exams. Many stakeholders now believe that the longer OSHA takes to revise its construction crane standard, the better the chance that certification will no longer be required, so operator training and qualification in the industry may go back to square one, which OSHA and the Cranes and Derricks Advisory Committee already concluded was not safe enough.

Interview #22- Large Construction/Crane Operator Training Company

I. Background
OSHA conducted a phone call with a representative from a large construction company based in the Midwest.  This employer often is the general contractor on major projects, such as construction of bridges, correctional facilities, roadways, educational facilities, and utility complexes. This company also gets contracted to provide crane operator training for other employers as well. The company employs trainers and assessors who have many years of operating experience. The company maintains a database of hoist directors/site supervisors and operators that they have encountered on projects; the database includes information about the kinds of work performed and the types and capacities equipment used. 
III. Operator Candidates
As a general practice, the representative estimated that it typically requires at least 1,000 hours of actually operating a particular type and capacity of crane before an operator is considered proficient enough to perform hoisting jobs without the supervision of another experienced operator. That estimate also varies depending on the types of hoisting jobs that the operator is tasked to perform at the jobsite. 
IV. Operator Training and Assessment
Training
The representative considers a good training program to include extensive hands-on operating experience, a written exam that verifies that a student has the basic knowledge needed for safe operation of the crane, and practical testing to verify that individual also has the skills to actually operate that type of crane. In the representative's opinion, capacity is important;   the longer the boom, the harder it is to control the load. 
Certification
The company would not allow an individual to operate one of their cranes based solely on the operator's possession of a certification. For example, before even an experienced and certified operator can be considered for solo operation of one of the company's crane of a different type, much longer boom length, or a different operating system, that individual must have operated a crane of similar configuration and design for an additional 1,000 hours, on average. Again, the skills necessary to safely operate the crane could vary drastically, depending on what the operator is assigned to lift.
Assessment
Operator assessment is on-going and an operators' employer should play a significant role in that assessment. As safety supervisor, the representative encounters operators on the company's jobsites whose skill levels span wide ranges. On the company's own worksites and the representative guessed most other sites out there, the operators are being constantly evaluated informally as they perform their work whether they know it or not. In a situation when the representative has observed an operator that looks shaky or has done something unsafe, he'd have the operator get out of the cab, tell him what was wrong. In the worst cases, he'd have a discussion with the union steward about the operator's unsafe actions. On non-union jobs, the discussion would be with the site supervisor and eventually with the operator's employer if necessary. On those types of sites, general contractors can issue notification letters to contractors and use their contracts as leverage for ensuring safety on the jobsite. 
When it comes to unsafe conduct of certified operators, there are webpages maintained by the certification organizations and local operators unions on which those actions can be reported. The representative cautioned that not as many operators' cards get pulled by some of those organizations than probably should be. Union operators are a small and extremely tightknit groups in particular regions of the country, almost like a clique. Therefore, because a union operator's unsafe conduct as reported is reviewed by board members that are made up of friends and relatives within those organizations, some operators maintain their cards and still get recommended for jobs that they probably shouldn't. That is another reason why employers should always assess the knowledge and operating skills of even experienced and certified operators with whom they have no job history. The representative also explained that more and more employers unfortunately, especially in the modern world of subcontracting and specialty trades, do not have the expertise to make such an assessment of operators. At least through the certification process, those employers are more likely to get some help in the form of requiring their operators to get 3[rd] party, supplementary operator training in preparation for certification testing. This alone would raise the level of crane operating expertise in the industry.
V. Concerns of the Company
The representative was concerned that a delay in the effective date of the certification requirements will allow employers to stop thoroughly evaluating their own operators. Instead, they will continue to gamble on operators that may not have had enough seat time to even build up a safety record, and because those records are clean, an operator could be considered safe. The company would like only experienced and safe operators in the cabs of cranes. Without having to train to obtain a certification, many operators will not get valuable hands-on experience until they eventually land a crane job and start doing hoisting jobs under worksite conditions. A construction worksite is not the place for a beginner to learn how to operate a crane. However, when properly supervised, it can be a place to improve the proficiency of what an operator should already know before even getting into the cab at the jobsite.
The representative was a bit more confident that employers performing the more complex lifts with bigger and more advanced cranes already demand a lot more skill and knowledge of its operator than OSHA would require. The representative warned that an uneven playing field that would be created with regard to crane operator experience in the industry and further cautioned that it would be a terrible mistake if OSHA's certification requirements were not retained as the result of reopening the record to revisit operator qualification requirements.  At a minimum, the representative offered that maybe OSHA should revisit the applicability of the certification requirements to some types of hoisting jobs performed with some types of lower level equipment.  For these and other reasons, the company recommends that OSHA require operator certifications in the year 2014 as originally published.
Interview #23- Sole Proprietor of Residential Home Building Company

I. Background

OSHA interviewed a sole proprietor business owner/crane operator from the Midwest. He owns one 38 ton/100 foot boom truck crane which he uses for primarily new residential construction work as a subcontractor, as well as some commercial construction, other types of residential installation and improvement projects, and snow removal work. He has more than ten years of experience operating cranes.

This owner/operator decided to start his own crane company after the construction company that he worked at decided to stop using their own cranes and operators. He bought one crane (the crane he has) from that company. That company had a relatively small crane operation, with three cranes and multiple operators. The owner/operator was in charge of the crane program at his prior employer. He was responsible for training all of the other operators who worked for that company. 

The owner/operator currently has no plans to expand his business to hire any other operators or purchase additional cranes. During the housing market's downturn, he considered getting involved with the local union as a possible way to increase work or have access to additional operators for jobs. Ultimately, however, he decided to continue as the sole operator of his company.
 
II. The Owner/Operator's Own Qualification

This owner/operator learned how to operate a crane after years of working in construction as a sider. When his employer decided to buy a boom truck crane, he was interested in becoming an operator. He already had a CDL at the time. He did not receive any formal training. The employer knew an experienced operator who he got to teach this individual the basics. The experienced operator provided informal training and observation for a period of a few weeks. Once the owner/operator was somewhat familiar with the crane, he began operating, and he improved through gaining experience. He started out with simple jobs, which became more complex as he gained experience.

Although this owner/operator did not get formal classroom training at the beginning of his crane operating experience, he ultimately completed two different operator certification programs, one after a few years of operating, and a second more recently. 

During the time that this owner/operator worked for the employer with three cranes, he stated that it would take up to a year to get fully familiar and confident with each new crane that he worked with, even though all were the same brand and all were boom trucks, because there were still many differences in how they worked.

III. The Owner/Operator's Qualification of Other Operators

This owner/operator ultimately was in charge of the crane operation for the construction company. As the company bought more cranes and hired additional operators, they looked within and also outside the company for individuals that had certain relevant skills and backgrounds. New operators already had a CDL and/or a background in operating heavy equipment such as loaders, forklifts, backhoes or farm equipment. The owner/operator informally trained all of the new operators by teaching them the basics of crane set up, maintenance, load chart use, rigging, safety and operation in the yard, and then riding with them in the cab. These individuals would slowly be given the opportunity to build skills out in the field. The new operators would operate under his direct supervision for at least a month, having the opportunity to do up to 4-6 different jobs a day. 

When he felt that they were truly ready to be independent, they would begin going out alone. There was no final "test," but this owner/operator would carefully choose which jobs and give them easier tasks, like setting beams, with the right contractors to build confidence. He would also get feedback on their performance from the contractors. As they developed more experience, they would get more complex jobs.

The training and qualification was done very informally. The scheduling ran through this individual, so he could easily control who each operator did work for. He would also informally address any incidents with the operators, rather than through a formal structure.

IV. Owner/Operator Business
As an owner/operator, contractors who hire this individual will often want a certification card, but they rarely require anything else. Occasionally they will look at the crane's inspection records. Most of his jobs come to him through word of mouth. As subcontractor, he manages the crane set up, and every aspect of the use of the crane on a work site. He gives contractors instructions for properly setting up the worksite so that he can safely operate (such as ground conditions, power line proximity issues), and he will have to correct set up issues if he arrives on site and something is wrong. 
Although this has not happened to him, he is aware that sometimes contractors will take an active role if they recognize very unsafe or problematic conditions created by subcontractor crane operators, because he has come in to fix these jobs when contractors ask the subcontractor to leave.
V. Operator Certification
This owner/operator has completed two different operator certifications. In both cases, he said he learned things he did not previously know or about recent updates in the crane industry, including some techniques he now uses. The first time that he did a certification training program, he learned a lot about load calculations that he did not know before, since the cranes he works with all have similar computer systems for calculating load capacity. He is glad he has certification, and he decided to do so because he did not want to lose work. Once the industry was moving in the direction of operator certification, he completed NCCCO's certification to stay ahead of the curve, because as a sole proprietor, he needs to have an edge. However, in general a lot of the things he learned in operator certification are not applicable to residential construction or the crane work he performs and he already knew much of what was covered as well, from his practical experience. He also noted concerns with the practical tests being done on equipment that is dissimilar from the equipment that an operator will actually use. 

In general, he supports operator certification, because he believes that everyone should be required to be on the same level/meet the same floor. Otherwise, uncertified companies will charge less, but provide an inferior, dangerous service. He said that if another operator is going to be on site at the same time as him, he feels more confident knowing they are certified.
Interview #24- Insurance Brokering and Underwriting Companies

I. Background
OSHA met with representatives of two insurance companies in the mid-Atlantic region to discuss how the insurance industry evaluates crane companies, crane operators and sets insurance rates for this market. 
The two employees of company #1were brokers and represent large clients (crane companies) as they purchase insurance. The employee from company #2 is an underwriter and serves as the technical analyst for the insurance company; he produces the insurance contract terms. The terms generated by the underwriter include the premium, retention amount (first losses that company will pay up to the retention limit), the deductible, various percentages the insurance company will pay for losses above the retention limit, etc. As a hypothetical example, the contract might say the client must pay the first $1 million in losses out of pocket, pay 30% of all losses between $1 and $10 million dollars, and pay 0% above $10 million. One important factor that is considered is known as having "skin in the game," which is having a high enough deductible that the insured company will take an appreciable financial hit if there are accidents. 
The brokers and the underwriter interviewed all specialize in very large accounts. The underwriter said for many of his accounts there were probably only 3 other large insurance companies that would be competitors for that client, since there are only that many insurance companies who are able to insure the largest companies in the industry. One of the brokers briefly characterized the crane company insurance market into three segments: 1) large national accounts; 2) "middle market" accounts; 3) and "mom and pop" accounts. Smaller clients tend to cover smaller regional areas, often have short-term jobs, may have smaller capacity cranes, less complicated lifts. Larger companies tend buy policies that have a high deductible, the smallest most often have "guaranteed loss" contracts (insurance company pays all losses), and middle market companies tend to be in between for the amount of risk sharing they do. Insuring crane companies takes a lot of specialized knowledge so there are not many companies in the industry. Bare rental clients often need even more specialized information. Another type of non-standard insurance possibility is "large risk alternative rating option" which is sometimes used for higher risk clients, and can be done by "non-admitted" insurance companies. "Non-admitted" insurance companies are those companies that are not approved by the state's insurance department and they do not file forms or rates with the state. "Non-admitted" is a category that is often used by higher-risk companies, because it gives them the freedom to use form [contract conditions] or price. Most of these insurance companies are licensed even though they are not "admitted." Only 10-15 companies insure the construction industry, and fewer than 10 write insurance for crane operations only.  Bare rentals are more specialized; most of the risk is shifted to the construction company that rents the crane. Insurance companies address operator qualifications in the contract.  
II. Factors considered by insurance companies when writing policies
Crane insurance generally covers four categories of risks: workers' compensation, general liability, automobile and truck transportation, and property and equipment.  For worker injuries, there may be lost wages, medical bills, or rehabilitation costs.
Concerning equipment loss, there is a schedule of the value of cranes, which reflects manufacturer, age, and market value (which fluctuates with the level of construction activity).  
In the insurance industry, history predicts the future.  Actuarial analysis predicts an employer's loss projection, typically for 5 years.  The loss history of a client will be looked at for the past 5 years.  A survey is done by a risk analyst [engineers], and this provides the data for the analysis.  
A broker and underwriter will look at the claims history for patterns, revenue level, and claims -- many factors are taken into account. Does the client use chase cars behind mobile equipment on roads?  Do those chase cars accompany the mobile equipment in front and back of the equipment? How does the client check training?  Does the client follow DOT requirements for commercial driving licenses?  The analysis attempts to identify trends in the data.  
They survey or collect information on:  the average job tenure of employees; crane operator wages; how the company evaluates employees; how does the client make the transition of an employee from laborer to crane operator; how do the staff work; is the operator assigned to the same crane every day?  They evaluate the appearance of the equipment.  
The goal of this analysis is to evaluate the Quality of the Risk. This goes beyond number crunching. A value of 1 to 100 is assigned to all of the factors considered. One of the most important considerations is what a client does after an accident: is there a thorough analysis of the cause? Do they develop new protocols to address any issues found?  
The company looks at the cause of losses:  If they see a high percentage of operator error, say 50%, that is a problem.  That client may be dropped.  They also examine training and retention efforts. The 4 major causes they see of crane accidents are: operator error, site preparation failure, equipment failure (if this keeps recurring will take a close look at maintenance program), and accidents due to weather (particularly wind).
Insurance companies also evaluate maintenance. How often is maintenance performed? How often are inspections done? What is the age of the fleet? Are ground and weather conditions (especially wind) paid sufficient attention. How much power does the operator have? 
All big claims are thoroughly analyzed by the insurance companies.  Losses are analyzed in two steps. First divide losses/events into categories. Then, determine how to manage claims. Large companies with large retention are fast and thorough.  There is an on-site investigation in the causes of incidents. They categorize incidents in terms of losses/frequency/severity. They may train clients.  
They consider all of these conditions to write the account.  Insurance companies want long-term accounts, and typically do not make a profit from the account for the first few years.  Experience modification reflects frequency, not severity.  NCCCI has data on workers compensation claims, for example; some states also have their own data:  PA, MI, NJ, CA.
The factors discussed above are considered pre-qualification. Some of this data may be used to calculate large risk alternative ratio options (LRAROs).  The underwriter hopes to improve quality of risk and tries to reduce risk.  
Workers comp and auto insurance are very regulated; same prices for all.  When the premium is big, the normal rules no longer apply.  
Insurance contracts tend to last one year. Three to four months before the renewal date, the broker will gather data that the underwriter will need in order to generate a quote for the new year (for a potential new client data needs will be similar though perhaps more difficult to get). These will include: 
   * exposure (amounts insured. [Note: this is not always a dollar amount. If a client is lifting aluminum they may write it on a premium price per aluminum lifted, versus dollar amount lifted so they're not exposed to any shifts in the price of aluminum over the year]) by policy year; 
   * losses by policy year (losses are the product of frequency and severity. Frequency is how often accidents occur; severity is the loss in an individual accident. So a low frequency high severity time profile of losses will be more variable than a high frequency low severity profile, and hence will be harder to insure, all else equal.); 
   * losses by type (bodily injury, general liability, etc.); 
   * workers' comp losses as a percentage of payroll; 
   * various other costs (ALAE-Allocated Loss Adjustment Expenses, costs to investigate claims, lawsuits, etc.); 
   * information on various accidents (OSHA logs, depositions of witnesses to the accident, etc.);
   * other performance characteristics of the company such as: 

            type/model/age/value of each crane, 
            average tenure of crane operators, 
            what pay scale for operators, 
            what are procedures for transferring a worker from another position into becoming a crane operator, 
            employee turnover, 
            maintenance program for cranes, 
            what kind of system in place to deal with and learn from any crane accidents, 
            what kind of investigation they do if there is an accident, 
            crane operator policies-particularly can the crane operator unilaterally decide whether safe to lift, 
            is the operator shielded from pressures by other employees to "get things done" when the crane operator feels an unsafe situation), typical type of lifts done (heavy lifts in tight spots versus lower weight lifts in open field, tandem lifts (more than one crane used on same lift) are particularly dangerous, etc.), 
            transportation conditions for cranes (typical routes traveled are heavily trafficked or not, have traffic manager, driver experience, support personnel/equipment for helping move cranes).
             
This underwriter will look at accident descriptions and how the company then reacts to these incidents and if he feels the company is learning and working on improving its safety program this will incline him favorably towards writing insurance for the company.
Guaranteed cost full risk transfer.  Under this type of insurance, experience modification very important.  
Some clients self-insure; this results in a very high deductible. There is no legal liability to buy general liability insurance.  Companies that self-insure know how to spend resources to reduce losses.    
Crane expertise is costly; claims are expensive. Insurance companies need underwriters who understand cranes; brokers evaluate the clients themselves. 
Insurance companies use revenues most commonly to determine exposure bases. That is a proxy for the number of cranes and their size. Look at the number of cranes in each size groups. Transportation is a significant source of crane employer risk. How does a company's risk fit into Quality of Risk? Look at the number of miles driven.  
An example of one business model or approach by an insurance company: they insure companies with low severity and high frequency accidents, and they are cheap.
Insurers have risk engineers or loss control specialists, including those who are crane experts. These individuals will do physical inspections of cranes, job sites (ground preparation etc.), and perform observation of crane operators. The underwriter's company has one crane expert who travels around to various sites to observe crane operators on the job.
Capacity at some broad level was an indicator of expertise level needed of operator. The electronics in newer cranes differ greatly across crane manufacturers; so crane operators often must specialize beyond, say "crawler crane operator," to "crawler crane of company X, model Y, operator."
III. Loss Data 
Possible sources for data on crane losses include National Council on Compensation Insurance (NCCI) -- for workers' compensation claims.  They have a class code for crane operator.  Also Insurance Services Office (ISO), which may have aggregated claims data for crane companies, especially small and mid-size companies. The underwriter stressed that ISO data tends to be submitted by the small and middle market companies (ISO often prepares insurance rate filings needed by individual state insurance regulatory bodies.  Larger companies have enough data that they can bypass using the industry-wide type filings that ISO can provide; they submit less data, hence ISO data will tend to just be the smaller players.)  They have basic loss data used in rate making for each state.  They recommend the frequency or rates to states.  
There is variation in workers comp rates between big, medium, small size companies.  
Small companies have much variation in fleet risks.  Small capacity cranes, usually mobile equipment with rubber tires, maybe a crawler crane. More short-term jobs  in close geographic area.
Middle-size companies have typically a combination of small and larger capacity cranes. More difficult lifts than small companies,  but not much engineering at the site and not multi-crane lifts. More units with computer controls; more automated cranes need equipment and mechanics to fix. 
Final notes:  If an operator is only qualified on one crane, it may be difficult to keep that operator fully employed.  Underwriters look for companies looking to grow (or drop ones that are shrinking). 
Interview #25- Insurance Brokerage Company (1 or fewer cranes)

I. Introduction/Background

OSHA staff met with a construction crane insurance broker. This insurer covers 800 crane companies nationwide.  Many of these companies are small customers, with 1 or a very few cranes.  Some of their customers have 50 cranes.  They insure cranes, trucks, and mechanics' vehicles. 
This company is a "program" insurer, as opposed to a "big box" company. Some insurance companies write policies for big companies  -  they are called "big box" carriers. Program insurers pick an industry or sector to specialize in. They are specialty risk carriers. This company only writes insurance for the crane industry, and only for crane owners (including entities that employ operators, and those that only own the equipment). 
Some insurance policies have "long tails," meaning that the insurance covers risks and occurrences after the crane has left the worksite. This company does not write this kind of policy  -  they write coverage for services, and their policies do not cover any events after the crane leaves the worksite, so they have no "tail."
60% of this company's customers are very small, with less than $25,000 in premiums. A "mom and pop" crane company with 1-2 cranes and little or low losses might have a $5,000 minimum premium. A very large customer could have a $500,000 premium.
II. Criteria in Evaluating Insurance Customers and Setting Rates
   
Factors that this company looks at in assessing the risks of a potential new customer include:
   * What services do they provide? What is their work?
   * Types of cranes
   * Number of cranes
   * How far do they travel for work?
   * Age and experience of operators
   * Whether Operators are certified?
   * Certified by whom?
   * History and nature of losses  -  Were they unlucky, caused by weak management, etc.?  
   * How does the customer investigate incidents?

Many customers will provide this company with insurance records from earlier years.  Agents get data from previous carriers. They question the previous insurance agent and sometimes the insured before accepting business or submitting a big policy.  
In considering customers, this company looks at the loss history.  The types of accident/incidents that this company most frequently sees are power line hits, crane overloads, and incidents over the road.  In reviewing customers, if there are too many incidents caused by crane operator error, that is a problem with the company overall. However, in many cases, due to the way the insurance is written, there frequently (70% of the time) may have been an indemnity for an accident that was not the crane company's fault.  This is because companies (and insurers) are forced by contract law to sign contracts to cover any claim of any kind, triggering any expenses that arise out the occurrences at the work site.  They are forced to write words similar to these:  "In addition to indemnity you will have to as initial insurer....your insurer will defend me and indemnify me" (the general contractor). The general contractor gets the crane company to provide that language in their contract.
This insurance company expects the loss ratio of prospective customers to be less than or equal to 40%; if it is above 40%, they look more closely at the prior claims.  Ninety percent of direct crane related costs/incidents are over the road events.  This company always requests driving history from previous employers of operators, although they may not get a reply. They also look at years of operator experience and history of the operator's employment on the crane that he or she is using.  If the company recognizes a pattern in the losses, there's a problem, since this indicates that the customer may not have discovered it or addressed it.  
Some of the biggest crane companies only bare rent cranes.  These companies do not have to carry insurance to cover others' activities and risks at the construction work site.  These bare-rental-only companies have the lower premium or rates per unit (crane).  
In this company's experience, most of the construction companies which own cranes are very large ones. However, it would be a mistake to assume that all small companies are not as safe as large ones.  Some small-- usually family-owned and operated--crane companies are very safe.  On average, smaller crane owners may have more incidents or a higher insurance rate (or experience modification), but many are very stable with few incidents.
Generally, the minimum premium is calculated approximately as equal to  rate x revenue  x  exposures (from loss history).
III. Crane Operator Certification and Qualification 
If operators are certified, this insurance company gives a 10% credit on policies -- if all operators are certified.  If only 50% are certified, the company would receive 5% credit.  This company will continue the 10% discount until all operators are certified.  This provides an incentive to the industry to train operators.  

When crane operator certification bodies began offering certification, the only evaluation crane operator received was an internal one.  The industry found that they needed a 3[rd] party to test the operator's knowledge base.  All operators need a training class to pass the certification test.  You cannot walk in off the street and pass the test. Certification occurs when an operator meets certain minimal criteria.  
This company noted that there is no load in the certification test, so this begs the question, Why is capacity important? An experienced operator should be able to control the hook on any capacity of crane. Type plus capacity for certification is just a financial burden for the employer.  
This company representative believes that operator certification alone, without the employer duty to ensure competence, would be worse than before the 1990s.  In this company's experience, the certification companies always said that certification did not equate with qualification. New operators must perform work under the strict guidance of the employer with many years of experience to become qualified.   Crane configurations also matter for operator qualification.
In earlier decades, a union could assign 2 men to work on any crane down to a 50 ton capacity crane. This provided an opportunity to train oilers, because they could be assigned to work with an experienced crane operator.  With competition from non-union companies, the 2-man crew began to deteriorate, from 50 to 80 to 100 to 300-ton cranes with just 1 operator.  That eliminated a primary source of new crane operators.  For very big cranes, there is increased safety from having two set of eyes. A problem occurs when the union needs a 300-ton crawler crane operator and only has a guy who has been running a 150-ton truck crane.
Note on training: it can be general and bland -- that is, it may not provide much experience or specific experience.  
Other note:  Keeping logs on operators in a "taxi" fleet, where an operator may move from crane to crane frequently, is very challenging.

Interview #26- Midsized Framing Company (1 or fewer cranes)

I. Introduction/Background

OSHA staff met with the owner and safety director of a midsized framing company which does framing work in several states in the mid-Atlantic region. A representative of the National Association of Homebuilders was also present.

This company has been in business for more than 30 years. It originally focused on residential construction projects local to the DC metropolitan area, but expanded to serve a greater area and to also perform construction on military housing and multifamily housing. The company uses cranes for many projects, and currently owns two truck cranes: one 60-ton rough terrain crane and one 40-ton truck crane. The company employs two crane operators. In the past, the company owned up to 4 cranes. 

In addition, the company rents self-erecting tower cranes and other cranes to complete jobs on an occasional business, and also occasionally subcontracts crane work to other crane operators. This company provides its own crane operator services about three-fourths of the time, and about half of that work is done with the cranes this company owns. This company will rent equipment the other half of the time, but provide the operator. This company rents self-erecting tower cranes for jobs where the mobile crane won't fit on the site. This company will also rent tower cranes with operators or work as a subcontractor with a general contractor that has a tower crane subcontractor on site.

In the past, this owner also ran an equipment leasing business that rented cranes to other businesses, usually with operators, but occasionally as bare rentals (usually with companies they knew well). 

This company used to have about 400 employees, but now it generally employs supervisors and uses subcontractors and oversees the work. 

II. Training new operators

When this company bought its first crane 30 years ago, a person with forklift, loader and manlift experience was chosen to become the crane operator. First, this person was sent to the crane manufacturer for several days to learn how the crane worked, and for another week to learn to understand load charts. Then this individual spent several days practicing using the boom with crane manufacturer representatives. After he came back from this training, the company had this employee practice using the crane in a field for several days and practice driving the boom truck. 

More recently, when this company had another employee that wanted to become an operator, who they felt had the aptitude, they took a similar approach and sent this individual to crane certification training and to take the certification exam. He also completed tower crane certification. After this, they had this individual practice using the crane under supervision in a parking lot, and brought an experienced retired crane operator in to provide oversight and on the job training. The safety manager and owner followed this new operator around until they determined he was ready to do jobs on his own.

Ultimately, the safety director and the owner make the final decision after getting feedback from those who have watched the operator to decide if that person is fit to go out alone and work safely. The safety director has several certifications including rigging, signaling and other certifications, although he is not an operator.

III. Evaluating experienced operators

This company has also hired experienced operators. This company would not let anyone operate a crane without evaluating them, even if they are certified. When this company hires an operator with crane certification, it takes steps to make sure that person can operate cranes. This company has considered certified operators who it did not ultimately deem qualified to operate equipment and did not hire.

When this company gets a trained and certified operator, the company will have them practice for about 3 days, and the supervisor will watch them for about 2 days to make sure they know what they are doing. A newly hired experienced operator would have a week or so to go through manuals for the assigned equipment and practice operation. They will operate the crane in a vacant field first to demonstrate that they know how to use the equipment in front of the safety manager, regardless of prior experience. Also, during the first few days on the job, the supervisor would be there to watch and make sure that this individual is qualified. 

Sometimes experienced operators are hired to do new types of work, and that also requires training and evaluation. For example, one operator was hired with prior experience setting pipe, who will now be doing roof trusses, so the supervisor must make sure that person can perform the assigned work. There are some aspects to setting trusses, such as visibility issues and the need to use signals that are different skills than would be required for laying pipe.

IV. Monitoring experienced crane operators

This company continues to monitor and train operators after they are evaluated. This company uses "Take 5s" at the beginning of the work day and safety talks to get everyone on the same page. The supervisors on a job will keep an eye on the operators, and if there is an issue the safety director will meet with the operator and foreman and determine if retraining is necessary. This would include near miss situations. The company will also take steps if there are weather issues, such as heavy winds, to decide what the appropriate response is, and whether to hold off on crane operators.
   
V. Requirements of general contractors

When the general contractor provides the crane and operator on a jobsite that this company is a sub at, this company has concerns because it has no say in the crane or the operator. If there are concerns, the only recourse is through the general contractor. When this company hires subcontractors, they have to monitor them.

When this company performs crane operations as a subcontractor, the types of information and level of scrutiny of the operator's qualifications by the general contractor varies:
   * Residential Construction: Generally the general contractor does not ask any questions about operator qualification and the operator does the whole job without anyone on site asking for certification cards or anything else. Occasionally larger national outfits will require more. 
   * Military Housing:  More documentation must be shown to the general contractor, including certification cards and the annual inspections from the cranes. Generally the Air Force and Army reserve the right to inspect the crane operations, but this happens very rarely. The Navy actually has a certified inspector review the crane's annual inspection and watches the operator operating, and inspects the crane. 
   * Commercial Projects: Large general contractors on commercial projects generally have more oversight as well, requiring a current inspection on the crane before work starts and have a safety director watch the crane set up and some operations, in addition to requiring certification cards. This is especially common with companies that self-insure.

Sometimes these requirements are part of the contract. This company's best practice, regardless of who the general contractor is, is to include all of this information in a tick list for starting a job and then they put this information on a screen and go through the list with the general contractors before work starts (along with other items, such as the site specific safety program, training program, Safety Data Sheets, etc.).

If a crane operator is obviously being unsafe, a general contractor would generally contact this company to let them know. This company has received very few complaints, however. The general contractor would also let this company know if there was an issue with the equipment.

VI. Operator Certification v. Operator Qualification in OSHA's standards

This company believes that certification does have value  -  it sets a baseline.  The certification should serve as something like a learner's permit, and then the operator needs to spend time in the crane and get familiar with the work and then be evaluated for that crane and type of work. This company believes that the most important aspect of crane operator training is hands-on training.

This company believes that the practical test under current certification requirements can be inadequate or irrelevant to real-life crane operation because the types of activities that those being tested must do are not practical to construction site work. Also, practical tests are often given on very old equipment that uses levers instead of joysticks or computer systems; therefore operators are not tested on a crane that is similar to what they would use on a worksite. The practical test should test more than "just swinging the ball."

The extensive testing on load charts under current certifications may also be overkill for residential construction, where this is not a large part of a residential construction crane operator's job. They are using the computer in the crane to follow what to pick up and there are safety features in the crane's operating system to prevent overextension. Load calculations would be used by operators performing typical residential construction work only a few times in their lives. The time spent learning load chart calculations could be better spent on different operating functions for operators performing quick and varied picks, such as residential construction operators. There should be more emphasis on the physical running of the crane.

There should be a third step to training and certification before an operator can operate independently with different classes for the different types of work that an operator is going to do. The operator should be evaluated on the crane he is actually going to run and be familiar with dangers and issues on the type of worksite where he is actually going to work. This should happen after the operator is trained and acclimated to the crane he is going to be running.

For example, residential construction uses lower capacity cranes to do different work which carries different hazards. When the cranes standard was being developed, most residential cranes were 30 tons or less, but now 40-60 ton cranes are more common in residential. These are different than a 100 ton crane. In residential work with a 40-60 ton crane, the operator is using every function on the crane to perform picks relatively quickly (50 picks in 2 hrs to set trusses). A different type of operator may use a 100 ton crane to do a complex lift and spend two hours planning 1 pick. Some other operators are going to perform purely repetitive lifts all day  -  e.g. swinging beams into place. Others are going to be doing blind lifts. These are different sets of training and skills. This company's operators would not dare do maximum critical lifts because they are not proficient in that. To qualify someone to do that, the operator needs to physically get in the crane and do it and the tester needs to verify that person is proficient for that scenario of work.

To train an operator requires a lot of time investment and cost. It is not possible to make sure that an employee doesn't get certified and then go to a competitor. This company has experienced this.  The third leg of operator qualification  -  the evaluation  -  which is equipment and job specific, could be something that is not transferable and unique to that employer. However, this company believes that national standards should be set so that everyone is on the same page about what is required for crane operator evaluation. The owner of this company also suggested that an OSHA standard should specify how much training operators need, such as a seat time requirement. 

VII. Other Issues

Self-erecting tower cranes: This company is concerned that the OSHA standard should more clearly address what standards apply for self-erecting tower cranes. They have been told to treat them as mobile cranes for certification purposes, but they believe there are differences and it is unclear whether a mobile or tower crane certification would be more appropriate (this company's operator has both certifications). Self-erecting tower crane companies will provide brief training/instruction on how to use the crane they are renting. With OSHA's standard, technology has moved so fast that the cranes standard may not cover everything on the market in terms of what certification is needed and what training is needed.

State and municipality-specific licensing/certification requirements: This company has found it difficult to comply with different certification and licensing requirements for crane operators in different states and cities. They believe consistent requirements across the country would make compliance easier. They also believe that training programs for crane operators should be standardized across the country.

Foreign Language training/testing: The owner of this company sees a change in the construction and crane industries  -  he does not believe it is as popular of a profession with young workers. The current generation of crane operators is retiring. He is concerned that workers that do not speak English, who are interested in operating cranes, do not have testing and resources available in a language they understand.
Interview #27- Framer and Manufacturer/Supplier of Framing Materials 

I. Introduction
OSHA visited a large manufacturer/supplier of structural wood framing materials and services to homebuilders. The services provided include framing homes (work after foundation is poured and before work is handed off to trades); however they are not considered the "homebuilder" in industry terms.  OSHA met with two employees, the Market Manager and the Install Manager.
II. Company Background
The company has two separate areas that require the use of cranes: manufacturing/delivery and installation.
III. Manufacturing/delivery
On the manufacturing and delivery side of the business, the work typically falls under general industry rather than construction. The company builds trusses, floor joists/trusses, and panels at multiple plants within a multi-state area of the country. Trusses are typically delivered using 48-foot roll-off trailers. Panels are typically delivered using a boom-truck crane.  The panels are delivered to the ground. The company also uses extended fork-lifts that allow for greater mobility, but add weight to the back of the truck, causing issues with state DOTs.  All operators of delivery trucks and cranes use for unloading are certified in house.
IV. Installation
The company will install any product they manufacture.  If the company installs the trusses and panels there is a company project manager on-site.  The company hires a subcontractor to frame the products. If a project requires a crane, their subcontractor will hire the crane service.   During busy construction periods,  crane operators are difficult to find, specifically ones with "certification" as defined by OSHA.  The company will recommend operators to the subcontractor and help the subcontractor find operators.  Some of the crane rental companies are owner-operators who own and operate a single crane.   The crane operator owns the crane and does not have employees. 
The project manager from the install company will observe the crane operator and note the level of efficiency and speed.  Does he have any difficult setting the crane up for operations?  When they talk with the operator, does he show familiarity with the crane, its operations, and construction terms?  If an operator is not up to the company's standards, the company will  remove the crane operator from the site, even though the subcontractor hired the crane operator.  
V. Comments
The company developed a safety program and all employees are trained. They require all subcontractors to have a safety program. If a subcontractor does not have a safety program, the company will help them develop one.
The company notes that if OSHA is looking to a similar system as used for training and certifying forklift operators, that system is not very meaningful in their eyes for cranes..  For example, the Install Manager is competent to certify construction forklift operators but is not himself an operator.  He said that would be inadequate for training and evaluating crane operators.  
The company would like to know the responsibilities of controlling contractors when the crane operator who is hired is an owner/operator.  Who qualifies the owner/operator?  What documentation would they have?  If, for example, a framing contractor hired an owner-operator crane rental service and "qualified" them under OSHA's draft regulatory text, is the person who "qualifies" the operator liable if there is a violation?  Since they hired the framing subcontractor  for labor to build the house frame, do they have a responsibility for the crane operator's performance or safety? 
The company does not consider itself to be crane "experts" and would like to know what they have to do to comply with the standard.
The company is pleased that OSHA is talking to employers of all kinds to gather information for this rulemaking.  In general, the company wants to provide a safe place of employment and is eager to find a workable system to ensure the safe operation of cranes on their worksites. The company has not had any violations or reported incidents related to cranes.  
Interview #28- Association of Building Material Dealers

I. Introduction
OSHA hosted a call with an association of building material dealers. OSHA staff, the association's regulatory counsel, a regional association representative who deals with smaller members and government compliance, and a member representing a mid-sized independent dealer participated on the call.
II. Association Background
The association represents its members in promoting the industry and working with regulatory bodies on matters that affect the industry. It represents large and small members.
III. Delivery of Building Materials
The industry typically uses articulating boom crane to bring materials to a work site where an operator drops the materials to the ground. Most of the deliveries are general industry or, if construction, are exempt from certification requirements in Subpart CC. Typical materials being delivered include lumber, roofing materials, drywall and other building materials. The crane is controlled from a top seat or from the ground by remote. Some deliveries may require placing the material on an upper level. When delivering to an upper level, the operator will need to hold the crane boom in place while the company who ordered the materials unloads them. The crane has built-in safety features that stop the crane from turning/tipping over. They use fixed-fork assembly, and no rigging. Deliveries are very similar to one another and the work of the operator is repetitious. They do not get contracts to operate cranes for framing work. They are aware of some delivery companies that do but those jobs are done with typical boom trucks and not with an articulating boom crane.
IV. Training and Operator Qualification
Training varies from employer to employer, but may often be similar to fork-lift training. The independent dealer that OSHA spoke with stated that his training typically starts with fork-lift training for new operators. The fork-lift training was developed by the association and has a classroom component, but the crane training may or may not, depending on the employer. Crane training is primarily hands on. Trainees start in the yard, under supervision of an experienced operator. Eventually the trainee moves to a delivery, where the trainee observes deliveries, then makes deliveries to the ground while supervised, and then elevated deliveries while supervised. Finally, the trained operator will make solo deliveries. 
Many delivery operators come from farming or other backgrounds with prior experience with heavy machinery or forklifts. Frequently, they will not have a high level of education so taking the certification exam could be a challenge. 
The articulating crane does not have a lot of configurations. For jobs that do require certification, such as construction deliveries using non-exempted cranes or jobs using older articulating cranes that do not meet the cranes standard exemption (none of the representatives indicated that they use these cranes, but acknowledge that some members may use these types of cranes) the association stated that the work is the same as the general industry and the exempted work. They are concerned that operators would have to learn things they don't need to know if required to complete certification for these kinds of lifts, and this could potentially take the focus off of the highly focused but limited range of movements delivery operators do every day.
The length of time it takes to train an operator varies. Some operators have prior experience and can be trained quickly, others take longer. The decision as to when an operator can make solo deliveries is left to the employer and supervisor. The employer would also talk to the experienced operator or operators who mentored the trainee. Once an operator is trained, some members will note this in a personnel file, but whether this is standard practice is not certain. Members with larger operations and larger delivery fleets will typically have more sophisticated training and evaluation procedures.
When a member hires an experienced operator he or she will review the resume, call references, and observe the operator in the yard and on deliveries to determine whether the operator is qualified.
Members get ongoing feedback from customers, which typically involves personality differences, rather than problems with the operation of the crane during a delivery.
If a company without an experienced crane operator is going to hire someone new, they will typically not hire a rookie, but will be more likely to hire someone with past experience if they cannot train the operator themselves, because articulating cranes are expensive equipment.
Operators typically do not need to read a load chard to operate the articulating boom crane. Most of the loads are packed to a certain weight in the yard that is a standard weight for the crane. If the load is too heavy the crane will stop the load from being lifted beyond a certain height or reach. If the load is too heavy, the operator will reconfigure the load into smaller loads on site. This happens occasionally when the distance from the crane to the delivery site is farther than planned.


