It finally happened. After almost ten years, on December 10, 2018, OSHA implemented the Crane Operator Certification law and licensing for those states requiring an operator license. But, that's not all they did!
In addition to implementing this law, OSHA upped the ante for training and raised the stakes even higher by mandating an Employer Operator Evaluation that went effect on April 15, 2019. As OSHA put it, it now is a three-step process for crane operators to be considered qualified — Training, Certification, and Evaluation. This article is the first in a series of three describing each of the three steps.
Historically, OSHA has generally required that crane operators be trained if it is found that they lack the knowledge and ability to operate the equipment safely. Beyond that broad requirement, nothing much more specific was stated or required.
As odd as this seems, the fact is that in the distant past, if an operator was formally trained, he or she was considered qualified, which may or may not have been true. To a large degree, crane operators only started to receive formal training in the U.S. in the mid ‘70s to early ‘80s, and it was sparse, and, at best, elementary.
Many crane operators, like me, started as oilers or trainees learning from the operators we served under. That less-than-formal training had its limitations. The depth of knowledge and the level of skill developed were directly related to the knowledge and skill of the operators we worked under and the particular cranes we were assigned.
My colleagues and I were fortunate to be under good operators who took a sincere interest in us and wanted to pass along their knowledge and skill.
Some others were not so lucky. If you got stuck with an operator who was insecure about his job and didn't take his training responsibility seriously, you didn't learn much, and your operating career didn't advance much either.
Getting assigned to the right cranes, particularly large complex mobile cranes with long booms was also important, especially for young guys like me who were eager to learn.
Looking back now, I was fortunate and thankful to learn under some very good and selfless operators who gave me opportunity and to be assigned to some big cranes with long booms.
In the late ‘80s, crane operators started to become certified, and formal training began to be more common. Nowadays, it is customary for almost all operators to go through some kind of formal training, and even a necessity if the operator wants to become certified. This is both good and bad.
The good is that any training is better than no training. The downside is that the cost of training, which includes time off the job and equipment costs, has resulted in less time allotted for training. In some cases, as little as only one day of training is provided and then the operator is expected to pass all the writ- ten exams, and many do.
You might ask, how in the world is it possible for an operator to pass all the written certification exams with so little training, especially tests covering complicated equipment like mobile cranes? As we will learn later, this is not considered training. You simply cannot adequately cover all the necessary information, particularly on mobile cranes, in one day.
In many cases, because of the limited time allotted for training and the pressure for operators to pass tests, the trainer resorts to teaching the test. In other words, the goal is to just teach operators just what they need to know to pass the tests. Teaching the test should never be the primary goal of training.
Additionally, the pressure for operators to become certified and the training money to be made has created a more sinister enticement involving cheating and, in some cases, theft.
Invariably, over time someone will get a copy of the test questions or the test will be reconstructed through a variety of means. It occurs more often with paper tests than with electronic testing.
This is why accrediting organizations like ANSI have such stringent requirements regarding test security.
Even though teaching the test results in a passing grade, those operators are not likely to go back to their jobs and contribute much to safety. The whole purpose of testing just went out the window, not to mention how much safety is compromised.
Surely that is not what OSHA had in mind when it set as a goal for training, "... to ensure that the operator-in-training develops the skill, knowledge, and ability to recognize and avert risk necessary to operate the crane safely."
To accomplish that requires more than a quality trainer. Even though we have a lot of good trainers in our industry, we are not delivering the level of training that we should.
What is lacking in most cases — and herein lies the problem — is the absence of a well-designed and developed training program, one based on a proven design and development model.
This isn't necessarily a reflection on the trainer. It may be that the trainer himself or herself does not possess the development skills to put together such a program. Program development requires different skills than those required to deliver training.
There could also be other constraints in play. Program development is time consuming and can be costly. Nevertheless, for training to be successful, the trainer must have a good program to deliver. This is so important that experts in the training field say that the program itself is 80 percent responsible for the success of the training.
The program is much like a racecar. Match a good driver with a great car and the driver is likely to do very well. Put the driver in a bad car and he is doomed to fail. The same holds true for good trainers who don't have a good program to facilitate.
For sure, the time and money spent putting together a good training program is well worth time and cost. Not only will the certification tests be less of a challenge, the operator will be better equipped because of his increased understanding of the crane and how the crane is to be safely operated on a jobsite.
At the Crane Institute of America, we use a systems approach when developing training programs. It follows logical process that focuses training efforts on the knowledge and skills operators need to do their jobs safely.
The model is called Instructional Systems Development (ISD). This particular model consists of a system containing five phases: analysis, design, development, implementation, and evaluation.
There are numerous benefits to following this model. During development and thereafter, the model is fluid and dynamic enough to allow for going back and forth between phases to make changes when necessary. You have confidence that once the program is finished and delivered, the results will be well trained operators who understand the information and how the information when implemented contributes to crane safety.
Also, considering the risks associated with cranes, this model provides a documentation of development if there is ever an OSHA investigation or liability issue regarding training.
Using this ISD model allows us to use a facilitative/participatory training style, in which the trainer guides the learner to discover what is to be learned. It is trainer-facilitated and learner-centered and has proven to be a better style for adult learners.
During delivery, we use very little lecture, as it is the least effective way for students to learn. Our style of training is far different than the commonly used "classical" style, which is based on the instructive or didactive method (lecture) and is teacher-led and subject-centered, not student-centered.
We have found that most operators-in-training are primarily visual learners, so we use a lot of visual aids, case studies, demonstrations, and other creative methods that are more comfortable for visual learners. When we train other types of learners, we change delivery methods to suit their preferences.
For any of you readers who want more information about learning styles, there are numerous books available about learning styles and the many facets of training and development. However, we at the Crane Institute have found the materials produced by the American Society for Training and Development to be very beneficial.
As the title of this article suggests, OSHA has really upped the ante regarding what it requires when it comes to training crane operators.
OSHA expanded what was once a very general training requirement to specific training topics or subject matter that must be covered, as applicable to the equipment being operated.
An important reminder for the reader is that the new training topics apply to all the equipment covered in the scope of the 1926 subpart CC. We tend to think only of mobile cranes when the subject of training or certification is discussed, when in reality there are many other types of equipment listed in the scope of subpart CC.
Looking back at operator certification and how it has progressed through the years, going from non-accredited to accredited certification, it is likely that training will follow this same path — particularly considering the expansion of OSHA's recent training requirements.
In the future, and it may not be that far away, training programs will themselves have to be accredited by a recognized accrediting organization like ANSI. Like certification programs, training programs will have to follow a similar process for accreditation. In fact, it's already being done in some parts of the country.
Thanks for reading this first of three articles on the three steps to operator qualification. The next one will explore the second step to qualification: certification.
James Headley is the CEO of Crane Institute of America. Headley holds a bachelor's degree in education and worked as a crane operator and oiler for 16 years before founding his company. He can be reached at jheadley@ craneinstitute.com.
(This story was reprinted with permission from CRANE HOT LINE, June 2019 issue.)