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OSHA 1917AppI

Cargo gear proof test requirements

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917AppI, how often must special cargo handling gear (purchased on or after January 21, 1998) be proof tested after the initial proof load test?

Special cargo handling gear purchased or manufactured on or after January 21, 1998 must be proof tested every four years after the initial proof load test. This recurring interval is specified in Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and is tied to the requirements of 1917.50(c).

Under 1917AppI, what are the testing requirements for intermodal container spreaders that are not part of a vessel's cargo handling gear?

Intermodal container spreaders not part of the vessel's cargo handling gear must be proof tested prior to initial use by an OSHA-accredited agency, must be proof tested prior to reuse after structural damage repair by an OSHA-accredited agency, and must be proof tested every four years (the four‑year test may be done by an OSHA-accredited agency or a designated person). These requirements are listed in Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and are referenced by 1917.50(c)(5).

Under 1917AppI, how do testing rules differ for gear that was already in service before January 21, 1998?

For gear in use prior to January 21, 1998, proof testing is required every four years starting on January 21, 1998; for certain ranges (20–50 short tons and over 50 short tons), prior to initial use or prior to reuse after structural damage repair the tests must be performed by an OSHA-accredited agency and must meet the specified proof-load criteria. See Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and 1917.50(c)(5).

Under 1917AppI, if special cargo handling gear fails a proof test after repair, what does the appendix require before reuse?

The appendix requires that gear be proof tested prior to reuse after structural damage repair; if a proof test fails, the gear must be repaired (or otherwise corrected) and then proof tested prior to reuse. This obligation to proof test prior to reuse is stated in Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and related to the enforcement provisions in 1917.50(c).

Under 1917AppI, may an employer use a "designated person" to conduct proof tests for large-capacity gear every four years?

Yes — for the recurring four‑year tests the appendix allows either an OSHA-accredited agency or a designated person to conduct the proof test (except where the appendix specifically requires an OSHA-accredited agency, such as certain initial tests or tests after repair for particular tonnages). See Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and the cross-reference in 1917.50(c).

Under 1917AppI, are the proof-test percentages (125% or 110%) absolute or do they vary by tonnage?

The proof-test percentages and requirements vary by tonnage as specified in the appendix: 125% SWL applies for many items up to 20 short tons (and for SWL ≤5 short tons in some cases), 5 short tons in excess of SWL applies for 20–50 short tons, and 110% SWL applies for gear over 50 short tons. These variations are listed in Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and cited in 1917.50(c)(5).

Under 1917AppI, does Part 1917 apply to a designated waterfront facility for the purpose of these proof-test rules?

If a facility is a "designated waterfront facility" (used solely for bulk storage, handling, and transfer of liquids or gases), Part 1917 does not apply to that facility; therefore the Part 1917 proof-test rules in Appendix I would not apply there. OSHA explains this non-applicability in the Letter of Interpretation "Applicability to waterfront facilities" at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31 and see 1917 for Part 1917's scope.

Under 1917AppI, does the appendix say who qualifies as an "OSHA-accredited agency" or a "designated person"?

Appendix I specifies when an OSHA-accredited agency or a designated person may perform tests, but it does not define the accreditation process or exactly who qualifies as a designated person within the appendix text itself; those administrative details are implemented through 1917.50(c) and related agency procedures. See Appendix I to Part 1917 for the testing table and 1917.50(c) for the certification cross-reference.

Under 1917AppI, does the appendix apply to spreaders that are part of a ship's cargo handling gear the same way as to standalone intermodal spreaders?

No — Appendix I distinguishes intermodal container spreaders that are not part of a vessel's cargo handling gear and provides specific testing requirements for those spreaders (for example, OSHA-accredited-agency testing prior to initial use and after repair). Spreaders that are part of a ship's gear are addressed under the vessel's cargo-gear provisions in Part 1917; see Appendix I to Part 1917—Special Cargo Gear and Container Spreader Test Requirements and 1917.50(c).