CUI C09.0 Attachment J-2 USS JACKSONVILLE - Work Item Package (Errata 5).pdf

THIS PERMANENT CHANGE UPDATES THE SPECIFICATION BID PACKAGE.

SHIP: USS JACKSONVILLE (SSN 699)

NWRMC-502-21

ERRATA NUMBER:

SPECIFICATION NUMBER:

THE FOLLOWING ITEMS ARE REPLACED:

992-10-001

DATED: 4/21/2021 11:02:28AMPage 1 of 1

SHIP: USS JACKSONVILLE (SSN 699) ITEM NO: 992-10-001 (E5)

COAR: 40 PCN: SSPS-L003

CMP: NONE

PLANNER: LEWIS, ANNA

COOPER, DANIEL

KOURLIS, MARINA

SSP: NWRMC-502-21 1 of 17 ITEM NO: 992-10-001

ERRATA NO. 5

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S.

International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S. Government. Violations may result in administrative, civil, or criminal penalties.

1. SCOPE:

1.1 Title: Contractor Facilities; provide

1.2 Location of Work:

1.2.1 USS Jacksonville (SSN-699) Puget Sound Naval Shipyard and Intermediate Maintenance Facility

1.3 Identification:

1.3.1 Not Applicable

2. REFERENCES:

2.1 Standard Items , (FY21)

3. REQUIREMENTS:

3.1 Contractor shall provide the following equipment and materials.

3.1.1 Shipment and deliveries shall be delivered to the north end of dry dock.

3.1.2 Office Trailers, approximately 10 X 20 feet, stackable

3.1.3 Connex box 8 feet x 10 feet for tool room

3.1.4 Forklift (propane)

3.1.5 Materials for a 45/90 Hazardous Waste/Material Storage Area measuring no greater than 10 feet x 10 feet.

3.1.6 Materials for building all work site containments and

protection that meets the requirements 2.1.

3.1.7 Explosion Proof Lighting

3.1.8 Flammable Storage Locker

3.1.9 Weld machines and welding support equipment

3.1.10 Scaffolding for contactor equipment and trailer/connex. (E5)

3.2 Submit request for weekday support services 5 working days in advance using Attachment A to the SUPERVISOR.

3.2.1 Submit request for larger support services 7 working days in advance using Attachment A to the SUPERVISOR.

3.3 Accomplish the lifting and handling requirements of Attachment B.

3.4 PSNS & IMF will provide the following equipment/materials and temporary services for Ex Jacksonville Project:

3.4.1 Electrical Power Hook - up for contractor furnished equipment

SSP: NWRMC-502-21 2 of 17 ITEM NO: 992-10-001

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S.

International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S. Government. Violations may result in administrative, civil, or criminal penalties.

and office spaces. ( up to 5000Amps)

3.4.2 Industrial (tool) air to within 50 feet from all contractor work sites/areas.

3.4.3 Rigging support

3.4.4 Temporary ventilation

3.4.5 PSNS & IMF will provide Dry-dock lay down area of 600 sq. ft.

3.4.5.1 Submit one legible copy, in hard copy or approved

transferrable media, of a report listing specific equipment dimensions and power needs to the SUPERVISOR at contract award.

3.4.6 PSNS & IMF will provide Pier lay down area of 400 (sq.20' X 35') ft.700 SQ/FT.

(E5)

3.4.7 PSNS & IMF will provide a covered hot work area 20 X 35'

3.4.8 No storage area is permitted on the vessel.

(V)(G) "STORAGE AND LAYDOWN AREA INSPECTION"

3.4.9 Accomplish a joint visual inspection with the SUPERVISOR of contractor storage and work areas dockside and in the dry-dock No. 2, 5 working days prior to completion of contract. Pier and dry-dock shall be cleaned of all contractor material and all waste generated by the work item requirements in this repair availability period.

3.4.10 Temporary shipboard scaffolding (E5)

4. NOTES:

4.1 Government installed air system manifolds require 1/2 inch male Hansen quick disconnect fitting for tool air hose connection.

4.2 Dry dock drawing will be made available upon award.

5. GOVERNMENT FURNISHED MATERIAL (GFM):

5.1 LLTM:

1. None.

5.2 PUSH MATERIAL:

1. None.

5.3 KITTED MATERIAL:

1. None.

SSP: NWRMC-502-21 3 of 17 ITEM NO: 992-10-001

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S. International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S.

Government. Violations may result in administrative, civil, or criminal penalties.

Attachment A

ASSIST WORK REQUEST

FROM (Supv Name, Shop, Phone/Pager) TO SUBMIT DATE REQUIRED DATE

PROJECT TWD/JOB ORDER

DECK FRAME P/S COMPARTMENT/TANK ACCESS LOCATION TLD:

YES ✔ NO

TASK DESCRIPTION (NOTE: Nuclear work accomplished by this request must reference and be controlled by appropriate documents.)

ASSIST. SUPERVISOR COMPLETION DATE

PSNS 4850/385 (Rev. 11-97) P

SHIP: USS JACKSONVILLE (SSN 699) ITEM NO: 992-10-001 (E5)

COAR: 40 PCN: SSPS-L003

CMP: NONE

PLANNER: LEWIS, ANNA

COOPER, DANIEL

KOURLIS, MARINA

SSP: NWRMC-502-21 4 of 17 ITEM NO: 992-10-001

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S. International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S. Government. Violations may result in administrative, civil, or criminal penalties.

ATTACHMENT B

SUBJECT: LIFTING ATTACHMENTS FOR CONTRACTOR FURNISHED EQUIPMENT (CFE)

Ref: a) 29 CFR Part 1926 Subpart H, Materials Handling, Storage, Use and Disposal

Encl: 1) OSHA Requirement and Interpretations

2) Examples of Special Custom Design Lifting Accessories

1. PURPOSE: Puget Sound Naval Shipyard and Intermediate Maintenance Facility (PSNS & IMF) personnel must adhere to strict requirements for lifting any equipment using cranes, including contractor furnished equipment (CFE). This document provides requirements for lifting attachments on CFE that will be lifted with government-owned cranes at PSNS&IMF incidental to repair work on ships, vessels and facilities. These requirements also apply to procurement or lease of equipment provided to the government.

NOTE: The requirements below are intended to provide a basic guideline for design of attachment points for equipment provided to PSNS&IMF and includes some of the most commonly overlooked considerations for crane-lifted original equipment manufacturer (OEM) and CFE items. However, this list should not be considered all inclusive. Contractor or OEM fabricated items must meet all applicable industry and OSHA standards.

2. REQUIREMENTS:

2.1 GENERAL REQUIREMENTS APPLICABLE TO ALL LIFTING ATTACHMENT POINTS:

2.1.1 Lift attachments for a four-point lift shall be sized based on either pair of diagonally opposing legs of a four point lifting assembly carrying the entire load for worse case of load distribution with respect to center of gravity. Lift attachments for three-point and two-point lifts shall be sized such that any two points carry the entire load based on worse case load distribution with respect to center of gravity.

2.1.2 The working load limit of each lift point shall take into consideration sling angular tension applied to each lift fitting due to minimum allowed sling angle incorporated into the lift design. Optimum sling angle is 60° with respect to horizontal. Sling angles for lift attachments shall not be less than 45° with respect to horizontal.

2.1.3 Location of lift points shall be symmetrical with respect to the equipment center of gravity and shall be in a common horizontal plane above the center of gravity. Equipment shall lift level, assuming all sling legs are equal length.

2.1.4 Orientation of lift points shall be such that when loaded the direction of force applied to each sling shall be ± 5° within the plane of the lift point (i.e. such as pad-eye or lug).

SSP: NWRMC-502-21 5 of 17 ITEM NO: 992-10-001

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S. International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S. Government. Violations may result in administrative, civil, or criminal penalties.

2.1.5 CFE designed to be lifted using a spreader beam shall be marked or have a placard attached to the equipment depicting the center of gravity and rigging configuration.

2.1.6 If equipment is intended to be stackable, provisions in the design shall be made to prevent damage to the lift attachments of lower units.

2.1.7 When test is required, test loads shall be held a minimum of two minutes.

2.1.8 All lifting attachment points must accommodate standard rigging gear (e.g., shackles, swivel hoist rings, etc.) If the lift requires use of specialized gear or an involved lifting gear arrangement, the special gear and/or a lift arrangement sketch shall be provided prior to delivery of the equipment for evaluation, approval and lift planning.

2.1.9 Swivel hoist rings, weld-on pivoting links, eye-bolts, turnbuckles, swivels, bolt-on pad-eyes, and similar rigging accessories are not suitable for extended outdoor use in a marine environment. These and similar types of rigging accessories shall not be used as aftermarket lifting attachment points unless specified in procurement documents. When swivel hoist rings are specified as lift attachments in procurement specifications, those shall meet all OEM requirements for thread engagement, material strength, mating to flat surfaces and perpendicular threaded holes.

2.1.10 Notify the project team 7 working days prior to delivery of CFE to allow for lift planning.

Submit an advance copy of any lift arrangement, sketches and specialized lifting gear that will be used along with delivery notification.

2.2 INTEGRAL LIFTING ATTACHMENT POINTS: Lifting accessories are lifting attachment points designed specifically for and fabricated as part of mass produced, commercially available original equipment manufacturer (OEM) items such as lugs, integral pad-eyes (i.e., not bolt-on), trunnions, lifting blinds, ISO container corner fittings and holes (threaded and unthreaded) that facilitate attaching rigging gear to the load are considered integral to, or part of, the load. These are suitable for use at PSNS &IMF provided the attachment points accommodate common rigging gear (e.g., shackles, swivel hoist rings, wire rope pendants/grommets, etc.) and comply with all applicable ASME visual inspection standards.

2.3 CUSTOM DESIGNED LIFTING ATTACHMENT POINTS: Custom design lifting accessories are lifting attachment points installed on equipment of unique design (i.e., not mass produced), as well as lifting attachments retro-fitted after mass produced item fabrication. Custom design lifting accessories shall comply with section 1926.251(a)(4) of reference (a). These shall be marked to indicate the safe working loads and be proof-tested to 125 percent of their rated load prior to use.

2.3.1 Requirements of 1926.251(a)(4) do not apply to mass produced, commercially-available equipment with lifting accessories specifically designed for lifting that OEM mass produced equipment.

Enclosure (2) provides examples of compliant and non-compliant CFE.

2.3.2 Certification documents shall be provided upon request for special custom design lifting accessories. At a minimum the certification document will include equipment nomenclature, serial number, test loads applied, duration of each test load and name and signature of the qualified person conducting the proof-test.

2.3.3 Special custom design lifting accessories installed after original equipment fabrication for CFE provided to the government shall be lift lugs, pad-eyes or ISO container corner fittings unless stated otherwise in the procurement contract.

SSP: NWRMC-502-21 6 of 17 ITEM NO: 992-10-001

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S. International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S. Government. Violations may result in administrative, civil, or criminal penalties.

2.3.4 OEM mass produced rigging accessories such as shackles, swivel hoist rings, weld-on pivoting links, eye bolts, turnbuckles, swivels, or other similar COMMON rigging components are deemed special custom design lifting accessories when retrofitted to mass produced, commercially available OEM equipment.

2.4 EQUIPMENT FOR CONTRACTOR USE ONLY: CFE used exclusively by the contractor that is not properly equipped with lifting attachment points (or has non-compliant attachment points) may be loaded by the contractor onto ISO flat racks, lifting skids, containers or similar lifting devices prior to transport to facilitate offloading/on-loading and lifting using cranes at PSNS&IMF. However, the lifting skid shall comply with requirements of 2.2 or 2.3 and 2.1.

2.5 CONTAINERS: Contractor provided sand hoppers, tubs, platforms, custom designed skids, pallets, and other containers that may contain liquid, solid, or slurry material shall be marked with empty and full weights. Full weights shall be established by the OEM. OEM must specify containers are suitable for lifting while loaded, otherwise containers will only be lifted empty. Containers utilized for trash, scrap or waste shall be open or accessible for rigger inspection prior to lifting. Containers holding liquids or slurries shall have baffles or other means to minimize shifting of content center of gravity. ISO shipping containers shall be marked with tare weight and maximum gross weight. OEM lifting points on hoppers, tubs, platforms, skids, pallets and other containers that were retrofitted, repaired or modified must of comply with section 1926.251(a)(4) of reference (a).

2.6 MATERIAL HANDLING EQUIPMENT: Manned elevated work platforms, aerial work platforms, forklifts, mobile cranes and similar machinery that may be lifted by crane shall be weighed and stenciled with the weight in pounds. OEM marked weights are acceptable. OEM lifting attachment points and/or lifting configuration shall be identified on the equipment or within operating manuals. Retrofitted, repaired or modified lifting accessories on these types of machines must comply with section 1926.251(a)(4) of reference (a). The fork lift drawbar shall not be used as a lift point.

2.7 DESIGN: Design requirements for fabrication, modification, and installation lifting accessories or special custom design lifting attachment points and lifting adapters, shall comply with industry standards such as:

ASME BTH-1, Design of Below the Hook Lifting Devices, Steel Construction Manual – American Institute of Steel Construction (AISC), AWS D14.1 – American Welding Society Specification for Welding of Industrial and Mill Cranes and Other Material Handling Equipment, or AWS D1.1 Structural Welding Code – Steel.

Special custom design lifting accessories attached to equipment procured by the government that will be lifted by cranes shall be designed and manufactured in accordance with ASME B30.20 and ASME BTH- 1, Category B. Alternatively, when using ASD from the Steel Construction Manual apply an additional factor of 1.8 to the nominal safety factor (i.e. Mn/(1.8 x 1.67). Mn is nominal moment from the Steel Construction Manual. Lift points shall have reserve strength to carry equipment self-weight plus 10% to account for potential future modifications, alterations or changes that could increase actual equipment weight.

Design of lift points and below the hook lifting devices shall be verified by a qualified engineer for adequacy per the requirements presented herein. Consideration shall be given to the loads imposed by the orientation of attached rigging gear, commonly known as sling angle tension. Calculations supporting the lift point design shall be submitted for PSNS Code 715 review prior to acceptance of the equipment.

SSP: NWRMC-502-21 7 of 17 ITEM NO: 992-10-001

EXPORT CONTROLLED DATA: This document contains technical information whose export is governed by U.S. International Traffic in Arms Regulation (ITAR). This information must not be transferred to a foreign person/entity without proper authorization of the U.S. Government. Violations may result in administrative, civil, or criminal penalties.

3 ADDITIONAL STANDARDS: Other standards that may be applicable to design and fabrication of lifting points or lifting structures:

ASTM A6/A6M, General Requirements for Rolled Structural Steel Bars, Plates, Shapes, and Sheet Piling ASTM A36/A36M, Carbon Structural Steel ASTM A148, High-Strength Steel Castings for Structural Purposes ASTM A322, Standard Specification for Steel Bars, Alloy, Standard Grades ASTM A325, Structural Bolts, Steel, Heat-Treated, 120/105 ksi Minimum Tensile Strength ASTM A449, Standard Specification for Hex Cap Screw, Bolts and Studs, Steel Heat Treated, 120/105/90 ksi, Minimum Tensile Strength, General Use ASTM A489, Standard Specification for Carbon Steel Lifting Eyes ASTM A490, Heat-Treated Steel Structural Bolts, 150 ksi Minimum Tensile Strength ASTM A668, Standard Specification for Steel Forgings, Carbon and Alloy, for General Industrial Use ASTM A1023/A, Stranded Carbon Steel Wire Ropes for General Purposes ASTM F541, Standard Specification for Alloy Steel Eyebolts AWS D1.1, Structural Welding Code – Steel, American Welding Society AWS D14.1, Specification for Welding of Industrial and Mill Cranes and Other Material Handling Equipment AWS 5.5, Covered Solid and Metal Cored (Composite) Electrodes for SMAW, American Welding Society AWS 5.28, Bare Solid and Metal Cored (Composite) Rods and Electrodes for GTAW, PAW, GMAW, and EGW, American Welding Society

OSHA REQUIREMENT AND INTERPRETATIONS

1 Enclosure (1)

Regulation

• Part Number: 1926

• Part Title: Safety and Health Regulations for Construction

• Subpart: H

• Subpart Title: Materials Handling, Storage, Use, and Disposal

• Standard Number: 1926.251

• Title: Rigging equipment for material handling.

• Applicable Standards:

1910.184(a); 1910.184(c)(2); 1910.184(c)(3); 1910.184(c)(5); 1910.184(c)(7);

1910.184(c)(10); 1910.184(c)(11); 1910.184(c)(12); 1910.184(f)(2); 1910.184(f)(3);

1910.184(f)(4); 1910.184(d) 1926.251(a)(4) Special custom design grabs, hooks, clamps, or other lifting accessories, for such units as modular panels, prefabricated structures and similar materials, shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.

OSHA INTERPRETATION

CASE 1

March 1, 2010 Letter # 20071113-8104 Re: Testing requirements for "lifting blinds" or "lifting covers" on pressure vessels

Question (1): Our company manufactures pressure vessels. We typically use custom-engineered "lifting blinds" or "lifting covers" (referred to collectively as lifting covers) on the top flange of the pressure vessels to enable the lifting contractor in the field to hoist the vessel onto the foundation and anchor bolts.

Section 1926.251(a)(4) says that special custom design lifting accessories must have their capacity marked and be proof-tested. However, the scope provision in §1926.251(a)(5) seems to indicate that those requirements apply only to slings. Is that correct? Do lifting covers also have to be marked and proof tested?

Answer (1): The lifting covers you refer to are required to be marked and proof tested; the scope provision in §1926.251(a)(5) does not exclude lifting covers from the marking and proof testing requirements of §1926.251(a)(4).

29 CFR Part 1926 Subpart H, Materials Handling, Storage, Use and Disposal, contains a number of provisions, including sections 1926.251(a)(4) and (a)(5), which state:

1926.251(a)(4):

Special custom design ... lifting accessories ... shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.

1926.251(a)(5):

Scope. This section applies to slings used in conjunction with other material handling equipment for the movement of material by hoisting ... The types of slings covered are those made from alloy steel chain, wire rope, metal mesh, natural or synthetic fiber rope ... and synthetic web ...

Subparagraph (a)(4) of §1926.251, and its attendant employer obligations regarding marking and proof testing lifting accessories, existed in Subpart H prior to the addition of subparagraph (a)(5) to §1926.251. Subparagraph https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1926.251 https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(a) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(2) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(3) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(5) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(7) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(10) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(11) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(c)(12) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(f)(2) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(f)(3) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(f)(4) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1910.184(d) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0251&src_anchor_name=1926.251(a)(4)

2 Enclosure (1)

(a)(5) was added when OSHA identified several existing general industry standards as being applicable to construction. OSHA listed those standards in the Federal Register and incorporated them into the portion of the Code of Federal Regulations where the OSHA construction standards are located (Part 1926).1

OSHA emphasized that the incorporation of those provisions into Part 1926 was simply a means of making it easier for the public to know which general industry requirements were applicable to construction; the re-codification of those provisions did not result in any substantive changes. This is reflected in the discussion in the preamble to this action:

This action does not affect the substantive requirements or coverage of the standards themselves. This incorporation does not modify or revoke existing rights or obligations, nor does it establish new ones. 58 Fed.

Reg. 35077 (June 30, 1993) (emphasis added).

In other words, the codification of a general industry provision as 1926.251(a)(5) did not limit the coverage of §1926.251(a)(4), which originally included, and continues to include, special custom design lifting accessories.

Furthermore, the purpose of the scope provision in subparagraph (a)(5) is not to limit the applicability of §1926.251 only to slings, but rather, with respect to slings, to identify which types of slings are within the scope of 1926.251. This is reflected in the language of subparagraph (a)(5):

Scope. This section applies to slings used in conjunction with other material handling equipment for the movement of material by hoisting ... The types of slings covered are those made from alloy steel chain, wire rope, metal mesh, natural or synthetic fiber rope ... and synthetic web ... (Emphasis added.)

In sum, Subpart H of 29 CFR Part 1926 covers various aspects of material handling. Within Subpart H, §1926.251 provides requirements for rigging equipment, as indicated by its section heading, "Rigging equipment for material handling." Such equipment includes, for example, custom design lifting accessories and slings.

Subparagraph (a)(5) addresses one type of rigging equipment - slings - for the purpose of specifying which kinds of slings are included in "rigging equipment for material handling."

Thus, along with other types of rigging equipment, §1926.251 applies to slings of the specified materials, when they are used in conjunction with material handling equipment to move material by hoisting. Note that the regulatory text does not state that this section applies only to slings. Rather, 1926.251 applies to certain types of slings and also to other types of rigging equipment, such as the lifting accessories referred to in subparagraph (a)(4). Therefore, 1926.251(a)(4) applies to the lifting covers you describe because these lifting covers are special custom design lifting accessories [see Question (2) below].

Question (2): The lifting covers are designed and custom-fabricated for the particular pressure vessels they are intended to lift and are typically not reused. Does §1926.251(a)(4) require these lifting covers to be proof-tested prior to use?

Answer (2): Section 1926.251(a)(4) requires the lifting covers you describe to be marked to indicate the safe working loads and proof-tested prior to use. Section 1926.251(a)(4) states:

Special custom design ... lifting accessories, for ... prefabricated structures and similar materials ... shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.

Our understanding is that the lifting covers are installed on the top flange of the pressure vessels to enable the lifting contractor in the field to hoist the vessel onto the foundation and anchor bolts. Such lifting covers are "lifting accessories" because they have been attached to facilitate the hoisting of the pressure vessels.2 They constitute special custom design lifting accessories because the lifting covers are designed and custom-fabricated for the particular vessels they are intended to lift. Furthermore, "prefabricated structures and similar materials" https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27299#footnote1 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27299#footnote2

3 Enclosure (1) include the pressure vessels you describe. Therefore, 1926.251(a)(4) applies, and these lifting covers must be marked to indicate safe working loads and proof-tested prior to use to 125 percent of their rated load.

CASE 2

http://osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25192 June14, 2002

Mr. Ron Pancari Project Manager Vogt-NEM, Inc.

4000 Dupont Circle, Suite 400 Louisville, KY 40207

Dear Mr. Pancari:

This is in response to your April 10, 2002 letter to the Occupational Safety and Health Administration (OSHA). In your letter and subsequent conversations with us, you have asked that we clarify how 29 CFR 1926.251(a)(4) applies to Vogt-NEM's spreader frame, strong back frame, shipping frame (ladder frame) and other lifting accessories depicted in the materials you submitted.

Since the sense we have of your inquiries is that they pertain to using these frames and other lifting accessories in the construction of power generation facilities, we have addressed your questions with respect to the obligations of an employer engaged in the construction of such power generation facilities with respect to 29 CFR 1926.251(a)(4). We are not addressing issues regarding contractual relationships with the owner, with the actual constructor or with the projects' various other contractors.

We have paraphrased your questions as follows:

Question (1): Must Vogt-NEM's frames and other lifting accessories depicted in the submitted materials be proof tested and marked prior to use according to 29 CFR 1926.251(a)(4)?

Answer: Yes, Vogt-NEM's lifting frames and other lifting accessories depicted in the submitted materials must be tested and marked according to §1926.251(a)(4) if they are used in a construction activity. This is the case irrespective of who supplies the devices to the construction employer (we have listed the affected pieces of lifting equipment below).

In your letter you describe the design and use of various Vogt-NEM, Inc. assemblies for the erection/installation of your steam generator tube bundles in power generation facility construction. You use this equipment first as part of the process for manufacturing the generator tube bundle. It is then used to ship, store, handle, move, and erect/install the bundle. All of the equipment that you have asked about function at some time as equipment designed to lift the bundle, and thus are lifting equipment/ lifting accessories (rigging equipment for material handling).

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25192

4 Enclosure (1)

We have identified the equipment or assemblies used in your construction activities under discussion as including those listed below and any others used in those activities, which fall under the requirements of 29 CFR 1926.251(a)(4):

From your April 10, 2002, letter and your May 7, 2002, UPS next day air letter:

Spreader Frame Assembly (for H.R.S.G. Module Tube bundle) Strong Back assembly (for Module Tube bundle) Installation Trolley Beam (for HRSG Module), if used as custom lifting accessory Additional Spreader Beam (for use with Strong Back atop Trolley Beam) Spreader Beam #2 (for use at bottom end of Strong Back), if used with optional crane #2 12 Lifting Bracket Assemblies (for use with tube bundle module lower tube wrap around) From Keith Kaufman's May 2 & 3, 2002, e-mails:

2 Steel Structure Spreader Beams Hoisting Beam (for Shipping Frame) Shipping Frame (for horizontal handling) Steel Structure Strongback Frame Steel Structure Top Hoisting Frame Additional Spreader Beam (for use with Hoisting Beam and Shipping Frame when only one crane makes the lift.)

As you described these assemblies and their uses, all are custom designed. In addition your procedures include complete inspections, repairs or replacements.

29 CFR 1926.251(a)(4) states:

Special custom design grabs, hooks, clamps, or other lifting accessories, for such units as modular panels...and similar materials, shall be marked [emphasis added] to indicate safe working loads and shall be proof-tested [emphasis added] prior to use to 125 percent of their rated load.

This provision does not permit calculations to be used in place of proof testing. The language is unambiguous — "Special design...lifting accessories...shall be marked to indicate safe working loads and shall be proof-tested prior to use to 125 percent of their rated load." Since all the equipment listed above, including your frames and assemblies are custom designs and are used to lift units such as modules or prefabricated structures, they fall within the devices regulated by §1926.251(a)(4).

Although the shipping frame changes uses as it goes through its life cycle, it is used as a custom design lifting accessory at least twice in that cycle and, as discussed during the May 3rd conference call, usually many more times. At the very least the shipping frame is used to lift and move its tube bundle in the bundle manufacturing process and during the installation process at the power generator. This accessory is used as a custom-design lifting accessory at several intermediary stages along the tube bundle's journey from creation to power generator construction activity and final installation.

Additionally, the shipping frame falls short of being an integral part of the product it surrounds. It has a short separate life both at its creation and after tube bundle installation. Your manufacturing process (as we understand

it) creates part of the shipping frame separate from and before the bundle's manufacture. Then the remainder of the shipping frame is tailored around the tube bundle as it is built. At the end of the frame life cycle it has a life separate and apart from the bundle as well. They separate as the bundle is lifted to its final position for installation. The shipping frame's separate life may be short after final bundle installation, but it is a separate

5 Enclosure (1) existence nonetheless.

We understand that the shipping frame is separated from its tube bundle at the installation phase of the bundle and then goes to scrap. However, the language of the standard does not differentiate among custom-design lifting accessories by length of life cycle or speed of demise.

In sum, because the devices and equipment discussed above are custom-designed lifting accessories, they fall under the requirements of 29 CFR 1926.251(a)(4) when they are used in construction and must be marked and proof-tested accordingly. The standard requires that each custom-designed lifting accessory be proof-tested and marked before being deployed for use.

Question (2): Must Vogt-NEM's frames and other lifting accessories depicted in the submitted materials be proof-tested and marked prior to use according to 29 CFR 1926.251(a)(4) after they have undergone repairs and replacements?

Answer: If a shipping frame or any other of the devices being discussed has been intentionally or inadvertently changed/modified, it essentially becomes a different custom-design lifting accessory. Therefore, after it has undergone changes that affect its safe working load, including changes during your repair and replacement procedures, Vogt-NEM's lifting frames and other lifting accessories depicted in the submitted materials must be tested and marked according to §1926.251(a)(4) when they are to be used in a construction activity.

Additional information

You indicated that the shipping frame/ladder assembly is constructed as the tube bundle is formed. Therefore, it is not fully assembled until the tubes are in it. This raises the possibility that it may be infeasible to proof-test the assembly, since it is not completed prior to the point at which it contains the tubes. If that is the case, the next most protective action must be taken. In the scenario you have described, this may consist of steps such as proof-testing a used shipping frame/ladder assembly and comparing the results of the proof-test to the calculated load capacity, use of safety factors in excess of what is required in the standard, appropriate manufacturing controls, and sampling methodologies.

If you require any further assistance, please contact [the Directorate of Construction].

Sincerely, Russell B. Swanson, Director Directorate of Construction

CASE 3

http://osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25212 Mr. Dan Wagester Siemens Westinghouse Power Corporation 4400 Alafaya Trail Orlando FL 32826-2399 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25212

6 Enclosure (1)

Re: Rigging equipment for material handling; custom-designed accessories.

Dear Mr. Wagester:

We are writing in response to your fax and letter of February 19, 2002, to the Occupational Safety and Health Administration (OSHA) Regional Offices. Your letter regards a lifting accessory that hooks to a crane and is designed to cradle/support heat transfer modules while being set into place during the field erection of a boiler system. As explained in our March 4, 2002, letter to you, OSHA's Regional Office sent your letter to the National Office. Since the letter addressed a construction standard, and you indicated that your concern relates to field erection, it was forwarded to this office for a reply.

Your letter focuses on §1926.251(a)(4) of OSHA's construction standards, which deals with rigging equipment for material handling, specifically, special custom-design lifting accessories. Under paragraph (a)(4), these lifting accessories are to be marked to indicate safe working loads and proof-tested prior to use to 125 percent of their rated load. You state that the "design/manufacture of the device has established the 'capacity rating' based on design calculations and manufacturing specifications." Your letter posed three interrelated questions regarding §1926.251(a)(4). We have rephrased the questions as follows:

Question (1): Under §1926.251(a)(4), must there be a proof-test at 125 percent of the manufacturer's rated capacity prior to use?

Answer: Yes. The standard specifically requires that custom-design lifting accessories must be marked to indicate the safe working load and proof-tested to 125 percent of their rated load prior to use:

Special custom design grabs, hooks, clamps, or other lifting accessories, for such units as modular panels...and similar materials, shall be marked to indicate safe working loads and shall be proof-tested prior to use [emphasis added] to 125 percent of their rated load.

Question (2): Under §1926.251(a)(4), after a proof-test at 125 percent has substantiated the manufacturer's rated capacity, are additional proof-tests required prior to further use?

Answer: No, the standard does not require additional tests prior to each use. However, if the lifting accessory undergoes changes that affect its safe working load, including changes during repair or replacement, it must be again tested and marked according to §1926.251(a)(4) if it is to be used in a construction activity. Note that the language of the standard does not differentiate among custom-design lifting accessories by length of life-cycle.

We addressed these requirements in an interpretation letter to Ron Pancari dated June 14, 2002. The letter explained that under §1926.251(a)(4), if a lifting accessory has been intentionally or inadvertently changed/modified, it essentially becomes a different custom-design lifting accessory. (A copy of the June 14, 2002, letter is enclosed.)

Question (3): Under §1926.251(a)(4), must all custom-design lifting accessories from a single manufacturer be marked with their safe working load and proof-tested at 125 percent of their rated load prior to use?

Answer: The need for this test depends on whether it is a "special custom-designed" lifting accessory. If the manufacturer mass-produces accessories, which are all of the same design, the standard does not apply to those accessories. If each unit is of a different design, then the marking/proof testing requirement would apply to each https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25192

7 Enclosure (1) one, even though they are from a single manufacturer.

If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Compliance Assistance, fax # 202-693- 1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely, Russell B. Swanson, Director Directorate of Construction

CASE 4

http://osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24541 July 7, 2003

Barry A. Cole Executive Vice President Miller Safety Consulting, Inc.

5750 Pecos Street, Suite #6 Denver, CO 80221

Re: §1926.251(a)(4) requirement for marking and proof-testing special custom-design or other lifting accessories

Dear Mr. Cole:

This is in response to your letter dated August 9, 2002, addressed to the Occupational Safety and Health Administration (OSHA) Office of Compliance Assistance in Denver, Colorado. Your inquiry was forwarded to the Directorate of Construction in the National Office. You ask about the Agency's policy concerning the use of engineering computations instead of proof-testing special custom-design lifting accessories. We apologize for the long delay in responding.

We have paraphrased your questions as follows:

Question 1: Does the §1926.251(a)(4) requirement that a "special, custom design lifting accessory" be marked and proof-tested apply to a custom-made lifting beam that has been designed by a registered professional engineer and made under quality controls?

Answer

Yes. 29 CFR 1926.251(a)(4) requires:

Special custom design grabs, hooks, clamps, or other lifting accessories, for such units as modular panels, prefabricated structures and similar materials, shall be marked to indicate the safe working loads and shall be proof-tested prior to use to 125 percent of their rated load.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24541

8 Enclosure (1)

If a grab, hook, clamp or other lifting accessory is not a regularly manufactured or produced item, the accessory is deemed a special custom design and must be "marked to indicate the safe working loads and proof-tested prior to use" in accordance with the §1926.251(a)(4) requirements.

We have included copies of letters to Mr. Pancari, dated June 14, 2002, and Mr. Wagester, dated August 15, 2002, that include extensive discussions of the issues you raise. In the Wagester letter the Agency concluded that:

The standard specifically requires that custom-design lifting accessories must be marked to indicate the safe working load and proof-tested to 125 percent of their rated load prior to use:

In the Pancari letter the Agency stated that:

Vogt-NEM's lifting frames and other lifting accessories depicted in the submitted materials must be tested and marked according to §1926.251(a)(4) if they are used in a construction activity. This is the case irrespective of who supplies the devices to the construction employer.

Question 2: Would the failure to do a proof-test be considered a De Minimis violation if the lifting accessory was made under quality controls and there is engineering computation documentation signed by a registered professional engineer?

Answer

No. Quality control and engineering computation documentation are not substitutes for assuring the performance of custom design lifting accessories through the required proof-test. As we stated in Pancari:

This provision does not permit calculations to be used in place of proof testing. The language is unambiguous -- "Special design…lifting accessories … shall be marked to indicate safe working loads and shall be proof-tested prior to use to 125 percent of their rated load." Since all the equipment listed above, including your frames and assemblies are custom designs and are used to lift units such as modules or prefabricated structures, they fall within the devices regulated by §1926.251(a)(4).

Question 3: Apart from §1926.251(a)(4), are there other OSHA construction standards that would be violated by using a custom design lifting accessory in construction without proof testing?

Answer

We cannot answer this question without more details concerning the type of equipment used and circumstances of the lift.

If you need any further information, please contact us by fax at: U.S. Department of Labor - OSHA, Directorate of Construction, Office of Construction Standards and Guidance 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, NW, Washington, DC 20210; although, there will be a delay in our receiving correspondence by mail.

Sincerely, Russell B. Swanson, Director Directorate of Construction

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by

9 Enclosure (1) mail at the above office, Room N3468,200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

EXAMPLES OF SPECIAL CUSTOM DESIGN LIFTING ACCESSORIES

1 Enclosure (2)

Examples of CFE currently in use within PSNS to clarify when the OSHA requirements for special custom design lifting accessories are required or not required:

Ex 1: ISO Shipping container corner fittings are an example of mass produced lifting accessories designed for lifting mass produced equipment (shipping containers). ISO corner fittings, a type of lifting accessory, is not subject to the requirements of 1926.251(a)(4) when installed on shipping containers built to the applicable ISO standard.

Ex 2: Circular or pear shaped holes cut in structural steel plates during the equipment manufacturing process in compliance with the OEM’s design that are designed specifically as lift points suitable to carry the weight of heavy machinery when lifted by cranes and rigging gear. This type of lift lug is common in many aerial work platforms, fork lifts, and other material handling equipment currently in use and is not subject to the requirements of 1926.251(a)(4).

Ex 3: A scrap metal container, which is normally loaded by dragging it onto a truck and dumping for offloading, is retrofitted with ISO container corner fittings to facilitate lifting by a crane. In this case the corner fittings would be considered a special custom design lifting accessory and must comply with the requirements of 1926.251(a)(4).

Ex 4: A chiller unit normally moved to various industrial site using a forklift is modified by attaching a weld-on pivoting link to the equipment to facilitate lifting the equipment with a crane to load into dry-docks for onto platforms incidental to ship repair work. Lifting D rings are mass produced rigging accessories. In this example, the D ring, a mass produced rigging accessory, became a special custom design lifting accessory to facilitate lifting equipment not originally designed to be repositioned frequently by a crane and is subject to the requirements of 1926.251(a)(4). The attached lifting accessory was not sealed in a manner to prevent water intrusion behind the welds and equipment is used in a marine environment which will cause corrosion under the pivoting link rendering the lifting accessory unsafe before end of equipment life cycle.

Ex 5: A mass produced forklift is equipped with lifting lugs located forward and above the front axle that are designed as part of the structural chassis of the vehicle. These are not subject to the requirements of 1926.251(a)(4). The rear lifting point designated by the original equipment manufacturer is the drawbar. This single lift point is below center of gravity and provides marginal stability when lifting the forklift with a crane.

This arrangement is not a common lift point. The primary design is for towing other equipment. Although a poor design for lifting, this unique application is considered a special custom design lifting accessory when used for lifting the machinery and must comply with requirements of 1926.251(a)(4). In this case the vender/OEM failed to comply with the requirements of 1926.251(a)(4) for the rear lift point.

Ex 6: Mass produced forklifts supplied to the shipyard were manufactured without lift lugs or other lifting accessory to facilitate hoisting this model into and out of dry docks. The OEM authorized the equipment supplier to bolt on lift lugs to the outside of the mast and outside of the counterweight compartment. In another case for the same model forklift, hoisting D rings were welded to the top of the mast to comply with the lifting requirement of the MHE rental contract. The retrofitted lifting accessories are considered special custom design lifting accessories. The contractor supplying the rental forklifts met the contractual requirement to provide forklifts that could be lifted using a crane, however, that contractor failed to comply with the requirements of 1926.251(a)(4) after installing aftermarket lift lugs and lifting D rings.