One question that is often asked, "Can I use a crane as part of my rescue plan?"
With the exception of positioning the load attachment point of a crane for a high-point anchor, or using a properly rated “personnel basket” to move rescuers and victims, the answer is typically “no” – except in very rare and unique circumstances. The justification for using a crane to move personnel, even for the purposes of rescue, is very limited. Be sure you have a clear understanding of the guidelines and precautions.
Both OSHA General Industry and Construction Standards severely limit the use of cranes to move personnel, and prescribe the proper safety measures for these operations.
Using a crane for rescue is not a carte blanche exception to the requirements of these standards unless very specific criteria are met. OSHA requires the use of personnel platforms when moving personnel with a crane. Personnel platforms that are suspended from the load line and used in construction are covered by 29 CFR 1926.1501(g). There is no specific provision in the General Industry standards, so the applicable standard is 1910.180(h)(3)(v). This provision specifically prohibits hoisting, lowering, swinging, or traveling while anyone is on the load or hook.
OSHA has determined, however, that when the use of a conventional means of access to any elevated worksite would be impossible or more hazardous, a violation of 1910.180(h)(3)(v) will be treated as “de minimis” if the employer complies with the personnel platform provisions set forth in 1926.1501(g)(3), (4), (5), (6), (7), and (8).
Even the use of a personnel platform is restricted. OSHA prohibits hoisting personnel by crane or derrick except when no safe alternative is possible. OSHA has determined that hoisting with crane or derrick-suspended personnel platforms constitutes a significant hazard to employees. Therefore, the hoisting of personnel is not permitted unless conventional means of transporting employees are not feasible. Or, unless conventional means present greater hazards (regardless if the operation is for planned work activities or for rescue). Where conventional means would not be considered safe, personnel hoisting operations meeting the terms of this standard would be authorized. OSHA stresses that employee safety, not practicality or convenience, must be the basis for the employer's choice of this method.
It’s important to consider, however, that in some instances such as when entering permit-required confined spaces, OSHA specifically requires rescue capabilities. In others, the general duty to protect an employee from workplace hazards would require rescue capabilities. Consequently, being “unprepared” for rescue would not be considered a legitimate basis to claim that “moving a victim by crane was the only feasible or safe means of rescue.” This is where the employer must complete written rescue plans (or ensure that their designated rescue service has done so), for permit-required confined space operations and for workers-at-height using fall arrest systems.
When developing these written rescue plans, it may be determined that there is no other feasible means to provide rescue without increasing the risk to the rescuer(s) and victim(s) other than using a crane to move the human load. These situations would be very rare; thus, requiring very thorough documentation which may include written descriptions and photos of the area as part of the justification for using a crane in rescue operations.
Here’s the key… Simply relying on using a crane to move rescuers and rescue victims without completing rescue plans with very clear justification would not be in compliance with OSHA regulations. It must be demonstrated that the use of a crane was the only feasible means to complete the rescue while not increasing the risk compared to other means. Even then, there is the potential for an OSHA Compliance Officer to determine that there were indeed other feasible and safer means.
In other words, using a crane as part of a rescue plan must have rock solid written justification demonstrating that it is the safest feasible means to provide rescue capability.
On the practical side, however, the use of cranes as “stationary, temporary high-point anchors” can be a tremendous asset to rescuers. It may also be part of a rescue plan for a confined space or a top entry fan plenum, for example. The use of stationary high-point pulleys can allow rescuers to run their systems from the ground. It can also provide the headroom to clear rescuers and packaged patients from the space or an elevated edge.
Of course, security of the attachment of the system to the crane and the ability to “lock-out” any potential movement are a critical part of the preplanning process.
Taking it a step further, where some movement of the crane may be required to do the rescue, extreme caution must be taken! It may require advanced rigging techniques in order to prevent movement of the crane from putting undo stress on the rescue system and its components. Rescuers must also evaluate if the movement would unintentionally “take-in” or “add slack” to the rescue system, which could place the patient in harm’s way.
Consider this, movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement must take place, rescuers must evaluate how it might affect the operation of the rescue system.
Of course, one of the most important considerations in using any type of mechanical device is its strength and ability (or inability) to “feel the load.” If the load becomes “hung up” while movement is underway, serious injury to the victim or overpowering of system components can happen almost instantly.
No matter how much experience a crane operator has, when dealing with human loads, there’s no way he can feel if the load becomes entangled – and, most likely, he will not be able to stop before injury or damage occurs. Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is lost when energized devices are used to do the work.
Applicable OSHA standards only restrict the “movement of personnel” with a crane. The same practical safety considerations that led OSHA to enact these standards should apply to decisions involving the use of cranes for rescue. For rescuers, a crane is just another tool in the toolbox – one that can serve as temporary, stationary high-point making the rescue operation an easier task.
However, once again, using a crane that will require some movement while the rescue load is suspended would be a “last resort” option! There are just too many potential downfalls and concerns associated with using cranes in rescue. This also applies to fire department aerial ladders, which are essentially the same thing. Rescuers must consider the manufacturer’s recommendation for use, who knows their equipment best. What does the manufacturer say about human loads? And, what about the attachment of human loads to different parts of the crane or aerial?
So, to answer the question, “Can I include the use of a crane as part of my written rescue preplan?”
Well, it’s yes and no. The use of any powered load movement will most likely be an OSHA violation, the question is, will it be considered a “de minimis" violation if used during a rescue? Most likely, it will depend on the specifics of the incident. However, you can be sure that OSHA will be looking for justification as to why using a crane in motion was considered to be the least hazardous choice.
Municipal Emergency Responders
This article was primarily directed toward private employers who control permit-required confined spaces and have Authorized Persons working-at-height while using fall arrest systems. When an employer fails to ensure that rescue preplans have been completed, or fails to inform a municipal agency that has agreed to provide rescue service to their facility about the types of rescues they may be summoned to, it places the municipal responders in a very difficult position. If municipal responders have not had the opportunity to complete a rescue plan ahead of time, they will have to do a “real time” size-up once on scene. Due to difficult access, victim condition, and/or available equipment and personnel resources, it may be determined that using a crane to move rescuers and victims is the best course of action. Ultimately, it is the responsibility of the employer to ensure that rescue plans are completed ahead of time. Planning before the emergency will go a long way in providing options that may provide fewer risks to all involved.
NOTE: Stay tuned for Part II of this story where we will talk more about the use of aerial fire apparatus as high-point anchors in rescue operations.