De-Rating of Mobile Cranes and “Adequacy” of Fall Protection Training
In recent months the Ministry of Labour has been encountering mobile cranes which have been de-rated (in lifting capacity) by a professional engineer at the request of the owner, apparently so that they could be operated by a Crane operator that has not completed a mandatory apprenticeship program.
The de-rating of new cranes or modifications which can easily be reversed does not meet the safety needs of workers on construction projects and will not be accepted by MOL inspectors.
De-rating of mobile cranes should be limited to older cranes and they must be permanently modified to safely hoist material at a lower load moment capacity.
With respect to Operator qualifications MTCU has confirmed the following:
If for example a 30 ton crane (requires the operator to have a 339A Mobile Crane Branch 1 Certificate of Qualification or registration as an Ontario apprentice to the 339A trade designation) has been de-rated to a lower lift capacity the requirement is that the operator have the minimum or greater requirement associated with the lift capacity of the de-rated crane.
Mobile Crane 0-8 ton – proof of training (Under OSHA)
Mobile Crane more than 16,000 pounds but no more than 30,000 pounds – Certificate of Qualification or registration as an Ontario apprentice in Mobile Crane Operator Branch 2 339C or the higher standard of Branch 1 339A.
Mobile Crane more than 16,000 pounds – Certificate of Qualification or registration as an Ontario apprentice in Mobile Crane Operator Branch 1 339A.
An engineer must sign of on the de-rating attesting to its maximum lifting capacity. The key words regarding classification for capacity is “capable of”, as noted in regulation (R.R.O. 1990, Regulation 1060 Hoisting Engineer), this means the crane when modified is not capable of lifting over a specified weight. If for example the operator can add another cable to a crane set for 8 ton or under and the additional cable(s) increase the lift capacity to beyond 8 ton, then the crane will be rated at its highest lift capacity for the purpose of determining operator qualifications.
The increase of the “adequacy” of fall protection training provided as a video or a web based instructional product also continues to be raised by employers.
It is the position of the MOL construction program that training provided on a video or web-based platform will not meet the intent of section 26 of regulation 213/91, as section 26(2) requires that the workers who may use fall protection be adequately trained in the use of fall protection systems and given written and oral instructions by a “competent person”. The limited interaction of video and web-based products will not meet the intention of this section and, even if a “competent person” produced a video it would be impossible for the trainer to verify that workers have successfully completed the training materials.
At this time Internet-based and video-based training materials should be used only for a more general level of fall awareness training, and will not be acceptable where workers will actually be exposed to the hazard of falling and use a fall protection system.
There are many options to provide adequate fall protection training for workers and it is up to each individual employer to assess the risks involved and provide adequate training for workers prior to the work being done.
There are a large number of fall protection “proof of training” cards circulating in the industry, and employers must take steps to ensure that adequate training has been provided regardless of the source before allowing workers to use fall protection systems.
MOL inspectors are not obligated to accept any proof of training card is adequate training, and depending on the situation and the demonstration of skills of the workers on the project will make individual determination if fall protection training has been adequate. I would urge all employers not to assign workers to work at heights or put their workers at risk, without the additional step of a demonstration of skills.
Michael Chappell
Provincial Coordinator
Construction Health and Safety
Ministry of Labour
By permission from the Ministry of Labour an excerpt from MOL Report to PLMHSC – October 21, 2012 on de-rating of mobile cranes and “adequacy” of fall protection training provided as a video or web based instructional product.