Directory of “Most Similar” Certifications
Navigating a Pathway to Compliance
OSHA’s Final Rule on crane operator qualifications requires crane operators to be certified [29 CFR 1926.1427(c)(2)]. However, in those cases where no accredited certification examinations for a particular type of equipment exist, OSHA states that “an operator will be deemed to have complied with the certification requirements of this section if the operator has been certified for the type that is most similar to that equipment and for which a certification examination is available.” [1427(d)(2)].
This requirement arose from a concern by the Cranes and Derricks Advisory Committee (C-DAC)—the industry group that wrote the document on which OSHA based its Final Rule published in 2010 (and the crane operator qualifications requirements of which were updated in 2018)—to limit the number of certifications an equipment operator should be required to hold. By establishing the requirement for certifications based on certain types of cranes, and addressing an individual’s competency to operate any equipment for which an accredited certification had not been developed, C-DAC (and, later, OSHA) felt they had reached an acceptable resolution. Thus, the “most similar” certification concept was borne.
That left the question as to how the certifications which most closely align to equipment for which no accredited certification exists would be identified. In other words, how are those “most similar” determinations to be made, and by whom?
OSHA provides a hint as to its intent and preference in addressing these questions when in the Preamble to the Final Rule it states:
” . . . the agency does not believe it is in the best position to determine the various types of cranes for which certifications should be necessary.” [Federal Register, Vol. 83, No. 218, November 9, 2018, p. 56217.]
and goes further to say:
” . . . it would be unwise for OSHA to consider a major change to the standard before the NCCCO Crane Type Advisory Group concludes its work which could include a consensus standard that identifies crane types that require a similar skillset and knowledge to operate.” [Federal Register, Vol. 83, No. 218, November 9, 2018, p. 56217.]
Crane Type Advisory Group
In expectation of the eventual need for guidance to industry in identifying the “most similar” certifications for equipment for which no accredited certification is available, the Crane Type Advisory Group (CTAG) was formed in May 2017 — prior to the publication of the Final Rule on crane operator qualifications — by the National Commission for the Certification of Crane Operators (NCCCO); responsibility for the activities of CTAG were transferred to the NCCCO Foundation in 2019 — which continues to operate the program as a fee-free public service to industry.
Comprised of crane subject matter experts with an unrivaled wealth of experience across a multitude of different types of cranes and applications, and representing literally hundreds of years of in-the-field, hands-on expertise, CTAG has been charged with the following mission and vision:
To provide authoritative advice and direction to employers and crane operators as to the appropriate certification for operators of different types of cranes
To ensure that no type of crane is left undocumented as to the appropriate certification required by the operator of that type of crane
Note that CTAG determinations provide a suggested means of compliance with the OSHA rule but they are not intended to reclassify the scope of existing certification programs.
The Most Similar Certifications Directory
The Most Similar Certifications Directory represents the determinations made to date by CTAG based on requests received from employers, training firms, regulators and other industry stakeholders. While CTAG makes every effort to make its determinations on a particular piece of equipment applicable to a whole type of equipment, some installations and/or equipment may be so unique that they do not lend themselves to generic categorization. Hence, the Directory is divided into three parts.
Part 1 – contains the determinations made for cranes for which no known accredited certification exists.
Part 2 – contains the determinations made for cranes for which an accredited certification does exist, but whose installation, application or the use to which it is being put may call the type of certification into question.
Part 3 – contains the determinations made regarding lifting equipment of a highly specialized or hybrid nature for which the appropriate certification is unclear.
Requests for Most Similar Determinations
CTAG meets regularly to review requests for determinations as to the most similar certification for equipment not covered by an accredited certification. Inquiries from industry stakeholders are encouraged. Requests for review should be sent to email@example.com with as much detail as possible about the equipment type in question, as well as its application.