Using a crane to move headstones and small monuments is “generally” not defined as construction, but the crane operator is still responsible for stringent worker-safety rules regarding crane operations, the Occupational Safety and Health Administration has advised in response to a question from an Arkansas granite and marble cemetery monument delivery company.

Sam J. Flocks, District 9 trustee of the Monument Builders of North America and a monument company owner, in a letter dated October 6, 2014, asked OSHA for guidance on its “cranes and derricks in construction” standard.

OSHA acting director of the directorate of construction Jeffrey A. Erskine first clarified that the business owner was requesting guidance on headstones and small monuments weighing between 100 pounds and 1,700 pounds, not larger mausoleums or columbaria, but still sometimes requiring assembly of several pieces, sealed with a water-resistant compound. He noted a crane is used to move the monuments or their pieces from a delivery truck’s bed either to the foundation or to a heavy-duty cart that is then pushed or pulled to a gravesite.

The OSHA official said that, based on rules in OSHA’s General Industry Standards (29 CFR 1910) and its Construction Standards (29 CFR 1926), pouring or installing a concrete foundation at gravesites for installation of a monument or headstone “would typically be considered construction work.” However, “simply moving a completed monument from the bed of a truck to the ground (or a completed foundation pad)” would “generally not be considered construction,” if it is done without “any alteration or improvement to the pad or monument following its placement on the pad.”

He further noted that it “would typically” be considered construction work if the job included “hoisting or positioning” of:

• a “completed monument onto or within formwork on the ground as the foundation is being constructed”;

• a “completed monument to where it would otherwise be joined or connected to another structure (including physically securing it to a precast foundation or securing its footings)”; or

• “several pieces of a monument during its assembly.”

It does not matter if the monuments are loaded to a cart or the ground, Erskine continued. What matters is “what will happen to the monument, or pieces of it, when transported to the jobsite.”

He also said that a crane with a capacity over 2,000 pounds, de-rated to less than 2,000 pounds, is still subject to the entire crane standard, not a lower standard, based on the crane’s maximum rated lifting capacity.