OSHA Compliance for Lifting Systems

Lately, my company has been asked to review numerous lifting systems for compliance to safety standards. I have been asked to review equipment that is a derived version of an existing device where the existing system DOES NOT meet the OSHA/ASME standards. Surprisingly, I find that the purchaser doesn't realize that they will be held accountable by OSHA for applicability of the lifting system usually resulting from an accident investigation or safety complaint. Did you know OSHA holds the employer responsible for design and applicability of lifting tools?

Handling and moving materials and products often requires special lifting equipment. Heavy lifting applications are found in both construction and maintenance applications. As the employer, you are responsible to ensure that all lifting devices are used appropriately and in compliance with the OSHA standards. Are you sure your lifting devices are in compliance?

OSHA 1926 provides clear instructions regarding the usage of lifting devices. Sadly, some companies find out too late that their lifting systems are not in compliance. How can you be sure that your system is safe and meets the OSHA requirements? To start:

• Ensure that all purchased products are designed to applicable industry standards, require a statement of compliance
• Ensure that each device includes operating instructions approved by a qualified engineer.
• Specifically applicable to below the hook devices (Ref: ASME B30.20, ASME BTH‐1, ASME B30.9):
• Require proof that the system was designed to meet the applicable standards.
• Devices shall include placards that list maximum rated load, serial number, design category (ASME BTH‐1), and device weight, device manufacturer.
• Devices shall include a placard that specifies date of last proof load test, date of lastinspection, and required date for next proof load test.
• Request the proof load inspection report.
• Require that all devices include maintenance and inspection plans.
• Use the device only in accordance with approved procedures, all deviations must be reviewed and approved by a qualified engineer.
• Any deviations or modifications to the lifting devices must be approved in writing by a qualified professional engineer

OSHA 1926.32 defines a qualified person as:

• 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.

Most states define a qualified engineer as one that is licensed to practice in that state (Professional Engineer). Please consult the laws of your state.

KTM Solutions is an engineering services company that specializes in lifting devices and material handling systems. All lifting designs are approved by licensed engineers (PE). Manufacturing services are available as well.

Need assistance ‐ Contact us at info@ktmsolutions.com

He Could Go All The Way

The phrase made famous by Chris Berman of ESPN. The receiver has the ball and is running down the field. As he approahes the end zone, the crowd cheers. They know that 6 points is just a few steps away. Normally, when that phrase is used, there is no chance of missing the touch down. But, then the unexpected happens. He drops the ball. The other team is right there and they recover the fumble. Celebration turns into disappointment.

Did you ever have an engineering project go that way? You thought everything was going perfectly. You were on the last leg and about to deliver when the unexpected happened. Somebody dropped the ball. Perhaps your parts didn't get ordered. Or maybe the wrong parts arrived. Or worse still, the engineering was wrong, parts were built but didn't fit when they arrived. Celebration turns to disappointment. Like the football player that drops the ball, this kind of foul up could cost you the game, maybe even your position on the team.

So what can you do? Can these mistakes be prevented? In short, yes. Good football is played by committing to the basics. Blocking and tackling. Protecting the ball. Moving the ball down the field. Unlike a football game, usually in an engineering project you are not fighting against an unfriendly opponent that wants to prevent you from moving forward. But, the basic mechanics of project planning and systems engineering must be followed to enhance your chances of winning the game.

Do you understand how system engineering works? Do you know how to identify risk areas, manage them, and mitigate the risks? Do you know how to integrate your team to keep everuone moving in the same direction? Need help delievring a completed system? Perhaps KTM Solutions can help. Let us help you. You could go all the way!

Dancing Naked on Table Tops

A long, long time ago at a company far, far away, one of my staff members wrote in status report that they "danced naked on a table top during their staff meeting." Obviously, this got my attention. I asked my staffer what this was all about. The associate told me that they didn't think that anyone actually read their report, so they put this in to see if anyone noticed.

Admittedly, I didn't always do the best and most thorough job of reading status reports. To be totally honest, sometimes I didn't read them at all. Many times, I just passed the information along to my bosses. In fact, I could easily have missed this one. But, thank heaven, I did read this report. The message behind the message got my attention. If you are a manager or leader, have you stopped to consider if your direction adds value, your requests are necessary, and if these requests are helping your team to succeed?

I had an influential boss named Jeff Peace. A very capable manager, leader, and unknowing mentor of mine. I learned a lot from that man. When I worked for him, he was the program manager on one of the large aircraft development programs at that company far, far away. He was unique from all the other managers I supported. He didn't care about status updates. Could care less about reports. In fact, when I sent him my first report, he told me that he gave me a responsibility and expected it to get done so why did he need a report? If I failed, I would be held accountable.

Don't get me wrong, he cared deeply about the project and wanted to know when we needed help. Afterall, his neck was on the line too. In fact, I can only imagine what it was like when he went to his superiors and they asked him, "How's the project going? Is it on schedule? Are there any issues?"  And his response would be ... "I assume fine" or "I haven't heard about any problems", or "Everything's going great?" but had nothing to show them. What a statement about responsibility, accountability, and trust. Jeff knew our capability and he trusted us.

Here are some things to consider and use as a test for yourself. Do you trust your people? Do you ask for reports and information that you never intend to use except to justify your position? Do your people feel ownership, accountability and a sense that they are trusted to complete the job? Does your team know that they will be held accountable but that they can also come to you for help anytime they need it? And, if they come, do you take the responsibility back or do you help them to succeed within their charge?

I don't know if he will ever read this blog, but thank you, Jeff, for trusting me and teaching me to trust those I manage and lead. As always, I welcome comments.

Should Engineers Be Registered?

In December 2013, I was asked to provide an overview of Aircraft Engineering to the Piedmont Chapter of the South Carolina Society of Professional Engineers. Recently, the legislature in South Carolina was petitioned to change the law exempting aircraft companies from the requirement of registration for their engineers. This stirred up a lot of questions in the PE community, particularly how aircraft engineering is regulated and accountable. Hopefully, these reflections will provide some clarity. And, of course, this is flavored with my opinion, too.

To be clear up front, I support certification of all engineers. When I go into a doctor's office, I am always appreciative to see that my doctor has been board certified and has demonstrated having met at least a minimum set of requirements. I encourage all our employees to take and pass the PE exam. At a minimum, a certified engineer should oversee and approve completed engineering. However, the PE exam is not the only way to be certified. In fact, I will go as far as saying, a PE certification may not be appropriate for aircraft design approval.

Next to the medical industry, arguably there is no other industry more regulated than the aircraft business. The Federal Aviation Administration (FAA) provides oversight for both the design and production of aircraft. Through the delegated authority process (FAA order 8100), qualified engineers assure that the regulatory requirements are met and that the aircraft type design is approved. Authority is delegated based on demonstrated abilities. Designated Engineering Representatives (DER) are the equivalent of a PE in the aircraft engineering business.

So, should states exempt aircraft companies from the legal requirements for state registration? I believe the answer is YES, provided that the aircraft company follows the FAA process. Many professional engineers fear that the aircraft exemption will lead to exemptions for other industries. Perhaps other exemptions are appropriate. But, a qualified certification program that demonstrates a minimum level of competency should always be a requirement. In most cases, state registration is the best choice.

The Drive That Captured The Moon

It's hard to imagine. 110 years ago, the Wright Brothers took their first flight. Consider how much has changed in 110 years. In fact, consider what took place in the first 60 years. From December 17, 1903 to July 20, 1969, roughly two generations, the industry went from the primitive powered flight to putting a man on the moon. What a great time to be an engineer. Think about how many technological advancements that came out of the space program.

Arguably, the 1960's was a decade of aerospace technology advancement like none other. In September, 1962; President John F. Kennedy made his famous moon speech at Rice University. The following is an excerpt from that speech.

"We choose to go to the moon. We choose to go to the moon in this decade and do the other things, not because they are easy, but because they are hard, because that goal will serve to organize and measure the best of our energies and skills, because that challenge is one that we are willing to accept, one we are unwilling to postpone, and one which we intend to win, and the others, too."

The Cold War fueled our drive to the moon. The Russians said that they would be the first to the moon. They planned to plant their flag to claim the moon for Russia. This increased the pressure to reach the moon. After Kennedy's death, Lyndon Johnson committed to continue the drive to the moon stating, “I do not believe that this generation of Americans is willing to resign itself to going to bed each night by the light of a Communist moon."

Does it take fear and war to drive American engineering? It's been 44 years since the first moon landing. Still, the United States is the only country to send human beings safely to the moon. Our engineers did it without the computing capability we enjoy today. They did it with slide rules, controlled testing, planned development, but most of all a drive that galvanized the nation. My question: Could we do the same thing today? What's happened to our spirit?

High school students aren't interested in engineering anymore. American students are more interested in writing gaming software, studying political science, or protesting for social justice. Meanwhile, foreign students are the overwhelming majority in graduate engineering programs and China is developing plans to send human beings back to the moon. What kind of challenge will revive American engineering? We need to recapture that spirit that put the first man on the moon.

Engineering Value

OK, I'll admit it. Yes. I have started to shop for Christmas gifts. I know it's only the first week of November. Actually, this early shopping is way off the norm for me. I disdain shopping crowds and wasting time in stores. Usually, I know exactly what I plan to purchase and wait until the last possible minute to get it. So, most of my shopping research is done at home on the Internet. Then I make my purchase when I know exactly what I want to buy for that special someone. In my research, I look for the best product and the best price. I want the best value.

I think we all look for the best value, however I don't think we have a common understanding of value. Value ties requirements to cost. The best product could mean a lot of different things. Value is not always the least expensive product. For example, I can buy an echo manual can opener for a whole lot less than a Hamilton Beach automatic electric can opener. Both do a great job, but one requires more work on my part. If I want to minimize my effort, the less expensive echo is not the best value for me.

At KTM Solutions, our company develops the engineering for new products that support a variety of industries. From aircraft structures to manufacturing automation, we support all areas. Value for one industry is defined differently than another simply because each has it's own unique requirements. Since all consumers want value (whether private or corporate), it is important that engineers understand the parameters that drive the value equation. In order to engineer value, proper and complete requirements definition is always the first place to start.

Are you getting the value you expect from your engineering team? If not, let's talk. Perhaps we can help drive value into your products.

Smart Systems - The Internet of Things

Have you heard of the Internet of Things? Although I have heard of similar ideas, this is a new area I've begun to study. Cyber links between machines. Machines"talking" to other machines. For instance, the technology allows machines to self monitor and sends feedback signals to other machines or human interfaces enabling preventative maintenance. Essentially, as the technology grows and machines are designed to self respond, machines will be able to self heal and continue down the path toward artificial intelligence. Does this sound far fetched? Not really. In fact, in some industries the machines have already begun to process diagnostics and perform internal maintenance.

Consider aircraft maintenance. For several years, the data management system has monitored aircraft systems and reported when maintenance was required. Some are beginning to be more proactive and diagnose potential issues. Another example, although less technical, automobiles are informing drivers when the oil needs to be changed and tires need air. Some automotive models also sense when collisions might occur. The latest BMW X5 will parallel park itself and can essentially drive its self on interstate highways.

So, given where this is going, it's not hard to imagine a world where machines are designed to take care of themselves. The machines will "know" when they need maintenance. Suppose the machine "determines" that a bearing needs maintenance. The machine will automatically submit an order for a replacement part and begin to limit the loads it will accept until the maintenance is accomplished. Perhaps the bearing is worn beyond use, so the machine will take itself off line, sends a message to a "partner" machine so that the partner can pick up the increased load. The machine will be notified when the replacement part arrives and either call for another machine to perform the repair or call the service technician. The Internet of Things - the technology is already here.

At KTM Solutions, this is a new area where we hope to play. As we continue to build our machine automation business, we want to include the benefits of the Internet of Things. We welcome your thoughts and would love to have you join with us.