From: Herrera, Attila (LNI) [herv235@LNI.WA.GOV]
Sent: Wednesday, March 23, 2023 3:59 PM
To: Jenna
Subject: L&I Inspection 317968030
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Jenna,
Good afternoon and thank you for taking my call this afternoon. As discussed earlier, I am sending you the Closing Conference highlights, for a General Violation, which has no monetary penalty. As I said earlier, I set a 30-day abatement period which does not begin until you receive the citation, which should give you plenty of time to get those inspections done. The Closing Conference highlights has all the details on posting etc., that we discussed during the closing conference. If you have any questions or concerns, please feel free to contact me.
Below are the references I was telling you about, the old ANSI/ALI ALOIM 2008 version and the current 2021 version which I received from our resident expert. I hope this helps, and although you may not need it, help you justify the expenditure.
It may be important to have the lift operate through the full cycle of movement to examine the entire length of wire rope while also using a ladder if synchronized from above. Another option is to use a “mirror on a stick”. This approach would allow you to examine the complete wire rope as opposed to just the parts that are exposed without movement of components or removal of covers.
Referencing the 2008 and 2008 (R2013) editions of ANSI/ALOIM that are now withdrawn standards, you should be looking at section 5.5 of those documents. This section clearly states “Qualified Inspection Frequency. Inspections by the owner or employer shall follow the recommendations of the lift manufacturer as to frequency. Without regard to the frequency of inspection specified by the lift manufacturer, whether it be weekly, monthly, semi-annually or on some other basis, the owner or employer shall ensure that the points present in 5.6 are inspected by a qualified lift inspector as a minimum annual requirement”. I’ve highlighted the important piece that you seem to have overlooked.
In the current edition that has been in effect since January 01, 2021 (ANSI/ALI ALOIM 2020), you would reference section 6.1.1
“Inspection Frequency. The owner or employer shall ensure operator examination points and the lift inspections follow the recommendations of the lift manufacturer and this standard as to frequency. In the absence of a frequency of inspection specified by the lift manufacturer, the owner or employer shall ensure that the points presented in 6.2.4 are inspected by a qualified lift inspector as a minimum annual requirement. I’ve highlighted an important piece here for you. You should also understand that “operator examination” is a visual examination that is not intended to be an equivalent of the work conducted by a “qualified lift inspector”. Should someone desire to argue this point, section 6.2.3 presents methods acceptable as training for a Qualified lift inspector. Annual inspection by a Qualified Lift Inspector should still be taking place as it was in the previous years you have cited.
Very Respectfully,
Attila Herrera
Compliance Officer, DOSH Region 4
Department of Labor & Industries
PO Box 44810
Olympia, WA 98504
Cell (360) 480-9797
Wk (360)-902-6084
HERV235@LNI.WA.Gov