The Knuckleboom Delivery Exclusion: Where Delivery Ends and Crane Work Begins

What 1926.1400(c)(17) actually says

The exclusion sits in the scope section of Subpart CC, 29 CFR 1926.1400(c)(17), and has three parts. Two describe activities that are excluded. The third lists conditions that cancel the exclusion even when the first two seem to fit.

• (c)(17)(i), ground transfer: an articulating/knuckle-boom truck crane delivering material to a construction site is excluded when it moves material from the truck to the ground without arranging it in a particular sequence for hoisting.
• (c)(17)(ii), sheet goods and packaged materials onto a structure: also excluded when it transfers building supply sheet goods or packaged materials from the truck onto a structure using a fork or cradle at the end of the boom, but only if the truck crane has a properly functioning automatic overload prevention device. The rule's examples are sheetrock, plywood, bags of cement, roofing shingles and rolls of roofing felt.
• (c)(17)(iii), the exceptions: the exclusion does not apply when the crane holds, supports or stabilizes material to facilitate a construction activity (such as holding it in place while it is attached), when the material is a prefabricated component, or when it is a structural steel member such as joists, beams or columns.

Testing a delivery against the rule

Walk through four questions in order. A no to the first, or a yes to any of the last three, puts the lift under Subpart CC.

First, is it a delivery with an articulating truck crane? The exclusion is written for knuckle-boom truck cranes delivering material. A telescopic boom truck or a mobile crane brought in to set loads is not covered by it. Second, where does the material go? To the ground, unsequenced, is clause (i). Onto a roof, deck or upper floor is clause (ii), and that requires both a fork or cradle on the boom and a working automatic overload prevention device. A truck without that device can make ground drops under the exclusion but cannot rely on it to land pallets on a structure. Third, does the crane hold anything while people work on it? Fourth, is the item a prefabricated component or structural steel?

• Pallets of concrete block set beside a slab in Montgomery: clause (i), excluded, if not staged in a hoisting sequence.
• Bundles of shingles boomed onto a roof deck in Daphne by a truck with forks and a working overload device: clause (ii), excluded.
• Drywall lifted to a second-floor opening and held while the crew unloads it board by board: covered, because the crane is holding material at an elevated work area.
• Roof trusses lifted off the truck on a new subdivision lot near Huntsville: covered, because trusses are prefabricated components.
• Steel joists or beams for a commercial building: covered, as structural steel members.

Trusses, precast and other prefabricated components

The prefabricated-component exception is where most Alabama building-supply drivers cross the line without realizing it. The rule's examples include precast concrete members or panels, roof trusses made of wood, cold-formed metal, steel or other materials, and prefabricated building sections such as floor and wall panels. Unloading a truss package with the boom, even straight to the ground, is outside the exclusion.

That has a practical result for truss plants and lumber yards. If drivers routinely deliver trusses, the drivers who run the boom need to be certified and evaluated as crane operators under 1926.1427, and the lift must follow the rest of Subpart CC, including ground conditions, power line clearances, signals and qualified riggers. The same goes for septic tanks, storm shelters and other precast pieces that a knuckleboom sets in place.

What OSHA's interpretation letters add

OSHA has addressed the exclusion in several letters of interpretation listed under 1926.1400(c)(17). In a June 23, 2016 letter to an articulating crane representative, OSHA described delivery as loads hoisted from the truck and placed on the ground without arranging them in a sequence for hoisting, or loads set on an elevated area such as a balcony, upper deck or roof before being unpacked from the pallets. Those activities are outside Part 1926. The same letter said the exclusion does not reach a truck crane that holds, supports or stabilizes building materials at an elevated work area so a construction activity can happen, even when the materials are palletized on forks. It also noted that the fork or cradle must be attached directly to the boom rather than hung from a load line.

A separate June 27, 2016 letter on propane containers concluded that initially placing containers on pads at a construction site is construction, so truck cranes doing that must comply with the crane standard. Lumber and building-material dealer groups have objected to parts of the 2016 guidance, and OSHA has said each case turns on its facts. Interpretation letters explain how OSHA reads a rule; they do not create new obligations. Check OSHA's interpretation database for anything newer before you rely on a letter for a specific task.

When a building-supply driver needs certification

A useful way to decide is to look at the driver's whole route, not a single stop. A driver who only drops block, brick, lumber and bagged goods to the ground, and lands shingles and drywall on roofs with a properly equipped truck, may never leave the exclusion. A driver who sometimes delivers trusses, sets precast, holds sheet goods at a window while carpenters pull from the pallet, or sets an HVAC unit onto its roof curb (OSHA treated a comparable placement of propane tanks onto pads as construction) needs certification for those lifts, and dispatch rarely knows in advance which stops those will be.

For that reason many Alabama dealers certify every boom driver rather than policing each delivery. It also helps with general contractors who require certified operators on their sites regardless of the exclusion. Two other points: excluded work is not unregulated, since general industry rules and Alabama's state law barring equipment within 10 feet of overhead lines over 750 volts still apply, as explained in our power line safety guide; and the certification exemption in 1926.1441 for equipment rated 2,000 pounds or less is based on the manufacturer's maximum rated capacity, so check the crane's chart rather than the weight of a typical load.

Matching the NCCCO articulating designation to the truck

When the work is covered, the operator needs certification from an accredited body for the type of equipment, plus the employer's own evaluation. NCCCO's Articulating Crane program offers three designations, and the right one depends on how the boom is rigged.

• Articulating Boom Crane (ABC): knuckleboom cranes using forks, a hook or other attachments without the winch. The common choice for building-supply and truss delivery fleets.
• Articulating Boom Crane with Winch (ABW): the same cranes when a winch and load line are used, typical for setting HVAC units, signs and poles.
• Articulating Boom Loader (ABL): loaders with a grapple or clamshell, used for logs, scrap, debris and bulk material, including storm cleanup trucks.

Getting a delivery crew ready

Each NCCCO articulating designation requires a written exam and a hands-on practical exam on the crane. The written exam can be taken by Online Proctored Testing, at a computer test center or at a test event; the practical is always in person. Certification is good for five years.

Our articulating crane operator course is self-paced online prep for the written exam, with exam-style practice questions that drivers can work through on a phone between stops. Yards that also set loads with telescopic boom trucks should look at the service truck crane operator course, and crews who sling truss packages benefit from rigger level 1. Dealers can enroll several drivers together through the enrollment form, and the Alabama crane certification requirements page lays out the employer evaluation step that follows certification.