Cargo handling gear proof testing

Yes — special cargo handling gear with an SWL greater than 5 short tons purchased or manufactured on or after January 21, 1998 must be proof tested prior to initial use, prior to reuse after any structural damage repair, and every four years after the initial proof load test. This testing schedule is set out in Appendix IV to 1918 and is implemented under the requirements of 1918.61.

• Initial tests must be done before the gear is put into service.
• Re-tests must be done after structural repairs before the gear is returned to service.
• Periodic re-tests occur at four‑year intervals after the initial proof load test.

Use the proof test specified for the gear’s capacity — the required proof load varies by rated capacity as shown in Appendix IV to 1918.

• For gear up to 20 short tons: proof test at 125% of the SWL.
• For gear from 20 to 50 short tons: proof test at the SWL plus 5 short tons (i.e., SWL + 5 short tons).
• For gear over 50 short tons: proof test at 110% of the SWL.

These proof-test values are the practical requirements employers must follow under 1918.61.

The initial proof test must be performed by an OSHA‑accredited agency. Appendix IV to 1918 requires that initial (pre‑use) proof testing for newly purchased or manufactured special cargo handling gear be done only by an OSHA‑accredited agency, consistent with 1918.61.

• Subsequent periodic tests (every four years) may be performed by an OSHA‑accredited agency or by a designated person as indicated in Appendix IV.

An OSHA‑accredited agency or a properly designated person may perform the four‑year periodic proof tests. Appendix IV to 1918 states that while the initial proof test must be done by an OSHA‑accredited agency, periodic re‑tests every four years may be carried out by either an OSHA‑accredited agency or a designated person, per the implementation of 1918.61.

Intermodal container spreaders not part of a vessel's cargo handling gear must be proof tested prior to initial use, prior to reuse after structural damage repair, and every four years after the initial proof load test, using a proof load of 125% of the SWL. This schedule and test load are specified in Appendix IV to 1918 and fall under the procedures of 1918.61.

If the gear was in use prior to January 21, 1998, the periodic proof test schedule depends on its SWL but generally requires testing every four years for gear over 5 short tons, starting January 21, 1998, and testing prior to reuse after structural damage repair. Appendix IV to 1918 lays out these schedules:

• For SWL greater than 5 short tons, testing was required every four years beginning on January 21, 1998.
• For SWL 5 short tons or less, testing is required prior to reuse after structural repair.

If the employer cannot certify that the gear was proof‑load tested under the prior 1918.61(b) provisions, then the gear must be proof load tested in accordance with 1918.61 as in effect on January 21, 1998 (see note in Appendix IV).

If the employer cannot certify prior proof testing under the earlier 1918.61(b), they must have the gear proof load tested in accordance with 1918.61 as of January 21, 1998. Appendix IV to 1918 explicitly states that gear in use before January 21, 1998 must be tested under the 1998 1918.61 requirements if the employer lacks certification of compliance with the prior rule.

Proof testing must always be performed prior to reuse after any structural damage repair. Appendix IV to 1918 requires that any gear that has undergone structural repair be proof load tested before it is returned to service, consistent with the testing rules in 1918.61.

Such gear must be proof tested prior to initial use and prior to reuse after structural damage repair, and the initial test must be performed by an OSHA‑accredited agency. Appendix IV to 1918 states that for gear with SWL of 5 short tons or less:

• The proof test is 125% of the SWL.
• Initial testing (before first use) must be by an OSHA‑accredited agency.
• Re‑testing after structural repair may be done by an OSHA‑accredited agency or a designated person in accordance with 1918.61.

Calculate the proof load by adding 5 short tons to the gear’s SWL. For example, if the SWL is 30 short tons, the required proof load is 30 + 5 = 35 short tons. This calculation method is specified in Appendix IV to 1918 for gear rated between 20 and 50 short tons, and the testing requirement is part of the 1918.61 proof testing program.

For gear with SWL over 50 short tons, the required proof test is 110% of the SWL. This requirement is set out in Appendix IV to 1918 and implemented under 1918.61.

No — a designated person cannot perform the initial pre‑use proof test for newly purchased or manufactured gear; the initial test must be conducted by an OSHA‑accredited agency. Appendix IV to 1918 requires OSHA‑accredited agencies to perform initial testing, while later periodic testing may be performed by either an OSHA‑accredited agency or a designated person under 1918.61.

No — securing wire rope by knots is prohibited by OSHA's standards covering material‑handling wire rope. OSHA has interpreted that wire rope shall not be secured by knots and cited related maritime and longshoring standards; see OSHA’s interpretation on wire rope knot prohibition at https://www.osha.gov/laws-regs/standardinterpretations/1977-12-14 and the maritime/longshoring rope provisions referenced in that letter.

• Employers should use appropriate terminations, fittings, or splices approved for the application rather than knots.
• This requirement complements the proof‑testing and safety rules in 1918.61 and Appendix IV to 1918.

Hooks used in longshoring should be latched or otherwise secured to prevent accidental load disengagement where appropriate. OSHA’s interpretation regarding hook latches notes that whether a latch is required depends on the activity, and that longshoring provisions specifically require that crane hooks be latched or otherwise secured (see OSHA's letter on safety latches at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0).

• See the longshoring standard and Appendix IV testing rules in 1918 for related hook and rigging safety requirements.
• Use latch‑equipped hooks unless the application makes the latch impractical; where latches are impractical, use other positive means to secure the load.

Yes — any modification that may affect a piece of equipment’s capacity or safety should be treated carefully, and proof testing or manufacturer/engineer approval may be required before returning the gear to service. While Appendix IV to 1918 sets proof testing requirements after structural repairs, OSHA enforcement guidance on equipment modifications (see the strobe‑light-on‑truck interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0) explains that changes affecting capacity or safety often require the manufacturer's written approval or approval by a qualified professional engineer.

• If a modification could alter safe operation or load capacity, obtain the proper approvals and perform required tests (including proof tests) before use.

Yes — Appendix IV separates requirements for gear purchased or manufactured on or after January 21, 1998 (Section A) from requirements for gear that was already in use before that date (Section B). Appendix IV to 1918 explains different testing schedules and who may perform the tests depending on that date of manufacture/purchase and prior proof testing history, consistent with 1918.61.

• The key difference is that initial pre‑use tests for new gear must be by an OSHA‑accredited agency, whereas gear already in use follows a schedule that assumes an initial test was already performed (or else it must be tested under the 1998 1918.61 rules).

Yes — Appendix IV specifically addresses intermodal container spreaders that are not part of the vessel’s cargo handling gear and requires 125% SWL proof testing prior to initial use, after structural repair, and every four years. Appendix IV to 1918 treats these spreaders explicitly; if spreaders are part of the vessel’s permanent gear, they would be subject to the vessel’s cargo handling gear program under 1918.61 and related requirements.

If gear fails the required proof load, it must not be returned to service until it is repaired and then proof load tested successfully prior to reuse. Appendix IV to 1918 requires proof testing prior to initial use and prior to reuse after structural damage repair, and failing a proof test indicates the gear is not safe for service under the 1918.61 program.

• Remove the gear from service, complete necessary repairs by qualified persons, and then perform the required proof test before returning the equipment to use.

Yes — if the employer can certify that the gear was proof load tested under the prior 1918.61(b) that was in effect before January 21, 1998, then the Appendix assumes the gear has been proof tested and the employer may follow the periodic schedule in Section B. Appendix IV to 1918 states that gear in use prior to January 21, 1998 was covered by the earlier 1918.61(b); if an employer can certify that prior proof testing occurred consistent with that rule, they may follow Section B schedules.

• If such certification cannot be made, the employer must have the gear proof load tested in accordance with 1918.61 as of January 21, 1998.

Yes — for gear in use prior to January 21, 1998, re‑tests prior to reuse after structural damage repair must be performed by an OSHA‑accredited agency (for some categories) or by a designated person depending on the SWL and category as shown in Appendix IV to 1918. The Appendix assigns testing responsibility by capacity and by whether the gear was new or in service before 1998, consistent with procedures in 1918.61.

• Employers should consult the Appendix table to determine whether an OSHA‑accredited agency or a designated person is required for a particular re‑test scenario.