Certification or Qualification?
Certification is better right? Maybe. What is the course? What is the topic? As for cranes and rigging, it is a matter of opinion. As you may know in 2018 OSHA came out with the final rule for mobile crane operators to be certified in construction. Let’s pause there, what does that mean “in construction”? OSHA has millions upon millions of laws. In our training, we focus on two, 1910 and 1926. Those are simply numbers and as they were written they came numerically for the most part. 1910 is called General Industry and 1926 is called Construction. I have heard many definitions for both but the one I like the most is a permanent or temporary work location. If it is permanent, it is General Industry. If it is temporary, it is Construction. Of course, I have heard that one is a vertical standard the other a horizontal standard, but as I said, I like permanent and temporary the best. So, in 2018 under the 1926 Construction law, OSHA put out the final rule that all Mobile Crane Operators operating in construction need to be Certified by a specific entity.
There are several entities out there but the one we use is the NCCCO. They have been around the longest and have a great amount of integrity. Before OSHA made it the law many states, insurance companies and safety professionals started mandated the certification as a matter of safety. I liked the idea of training and further education but what happened was there was a false impression that all crane accidents would stop. So, you have a license to drive a car that means you will never get into a car accident huh? Or you’re 16 as soon as you got your license you were the best driver in the world in fact driving a race would be easy huh? Please understand my sarcasm. My point is many see the certification as the end. OSHA has fixed this as well. I will talk about the addition to qualification after I finish with Certification.
So, do you need to be certified? Are you a crane operator operating in Construction? Yes. But there’s more to follow. Are you a crane operator operating a crane at a power plant? Under OSHA no. Your employer may have a requirement for you to be certified and that is where I have an issue. The certification is general and vague. If you run one type of crane or only that one crane all the time at the same work location don’t you think it would be better to be trained on your specific machine at your specific work location? I do. That is why we offer qualification training. This is where we investigate what crane you have, where it works, what you pick up and we build a program for those parameters. We take you through your responsibilities under OSHA, your company policy and best industry practices. So, if this is better why don’t we all do just this? It is hard to find the right training company. You have seen companies that perform training and they offer everything from Industrial Hygiene to Welding. So, they may have a qualified instructor, or they have an instructor that can read a powerpoint slide. We only teach what we know. To be a qualified crane operator you need to know how to set up the crane, evaluate the work conditions, understand the operator’s manual and load chart. Maybe most important, operate the crane in a smooth controlled manner. You can’t learn all of that in a book. You need to have someone that has the knowledge and skill to tell you how to do something, then show you how to do something. That is what we do.
So, the last thing, qualified is it is required by OSHA. There are several laws that speak to understanding, designated and being able to recognize hazards. These are all done by qualified people. OSHA has a great definition for qualified:
“Qualified” means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.
So, the argument comes up from those that read the definition a certification card is recognized therefore by definition the crane operator is not only “Certified” but “Qualified”. Well OSHA knew that too and in the construction standard they stipulate certified does not mean qualified.
Now again this is the construction standard. 1926.1427(f) Evaluation. 1926.1427(f)(1) Through an evaluation the employer must ensure that each operator is qualified by a demonstration of: then they list many topics.
They also stipulate: 1926.1427(f)(3) The definition of “qualified” in §1926.32 does not apply to paragraph (f)(1) of this section: Possession of a certificate or degree cannot, by itself, cause a person to be qualified for purposes of paragraph (f)(1).
Under General Industry 1910.180 they have a definition called “Designated”. Because under 1910.180(b)(3) it reads only designated personnel shall be permitted to operate a crane covered by this section. This means General Industry. The definition: 1910.180(a)(21) “Designated” means selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties. So again with “Qualified”.
Certification is great. It is done to a certain standard and is difficult to fake. Qualification is just as good if done correctly. An argument could be made for there is room for interpretation with qualified as well ambiguity. But my rebuttal is, if done with integrity they are both useful.