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Should Vs. Shall: How to Read OSHA Crane Safety Regulations

Chris Brewer
District Trainer

In OSHA’s overhead and gantry crane regulations, 1910.179, there’s more to the words “should” and “shall” than meets the eye.

You might guess that, when coming from OSHA, “shall” leaves no room for negotiation in regard to crane safety.  And you would be right. When OSHA says “shall,” that is the way it shall be, or you shall be paying a fine.

“Should,” on the other hand, is not as clear-cut. “Should” indicates an OSHA crane safety recommendation which must be considered and evaluated on a case-by-case basis by a  designated crane safety expert – for instance, a qualified crane consultant such as a Konecranes inspector. Based on the circumstances of a given crane, such as its working environment, how it is used and the level of training completed by personnel operating the crane, the designated expert could turn an OSHA “should” into a “shall,” requiring the crane to comply with OSHA crane regulations.
This falls under the general duty clause of OSHA, which states that employers shall provide a place of employment that is free of recognized hazards.

When it comes to “should” versus “shall,” another section of OSHA regulations comes into play – OSHA 1910.6. Through 1910.6, OSHA incorporates the mandatory (“shall”) regulations of specifically referenced government and nongovernment authorities, such as the American Society of Mechanical Engineers (section B30.2), the Crane Manufacturers Association of America, original equipment manufacturers’ technical manuals, and industrial regulatory bodies.

OSHA 1910.6(a)(1) states, “Only the mandatory provisions (i.e., provisions containing the word ‘shall’ or other mandatory language) of standards incorporated by reference are adopted as standards under the Occupational Safety and Health Act.”

As you can see, just knowing the “shoulds” and “shalls” of is not enough. While employers are commonly familiar with OSHA crane regulations because they are easily accessible and free of charge, many are not knowledgeable in the other standards referenced in 1910.6. Those other standards can be had, but only after paying a fee. Familiarity with those crane regulations also comes at the expense of wading through many pages (or in the case of ASME regulations, 29 volumes) that pertain to cranes.

Because it’s difficult to keep up with all of these standards, working with an overhead crane consulting expert, such as a Konecranes certified inspector, is a hassle-free way to go. Konecranes maintains a library of reference material and ensures continuous training of certified inspectors so that they have the up-to-date knowledge and experience to evaluate the facts of each situation.

For more information on crane safety, contact a Konecranes representative today.