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OSHA 1919.11

Recordkeeping procedures for accredited persons

Subpart C

17 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.11(a), what records must an accredited person maintain?

An accredited person must keep records of all work performed under subparts D and E of Part 1919. These records include documentation of tests, inspections, examinations, certifications, and any work performed on vessels' cargo gear as required by 1919.11(a).

  • Keep clear entries so you can show what was done, when, and by whom.
  • Make sure records cover both routine and non-routine activities under subparts D and E.

Reference: 1919.11(a).

Under 1919.11(b), what is meant by maintaining a 'continuous record of the status of the certification' of each vessel issued a register?

You must keep an ongoing record that shows the current certification status for every vessel for which you issued a register—this means documenting initial certification, renewals, suspensions, expirations, or other status changes. The requirement is stated in 1919.11(b).

  • Include dates of certification and expiration, any restrictions, and follow-up actions.
  • Update the record whenever certification status changes so it reflects the vessel's present standing.

Under 1919.11(c), who can examine the records required by paragraphs (a) and (b)?

The records required by paragraphs (a) and (b) must be available for examination by the Assistant Secretary. This right of inspection is specified in 1919.11(c).

  • Have records organized and accessible so an OSHA representative (the Assistant Secretary or authorized designee) can review them on request.

Under 1919.11(d), if I perform annual or quinquennial tests on a vessel whose register was issued by another accredited person, what must I provide to the original issuer?

If you perform annual or quinquennial tests, inspections, examinations, or heat treatments on a vessel originally registered by another accredited person, you must provide copies of any certificates you issued and information about register entries to the person who originally issued the register, as required by 1919.11(d).

  • Send full copies of the certificates you issued for the tests or examinations.
  • Include any register entries or changes you made so the original issuer can update their records.

Under 1919.11(e), when must an accredited person inform the nearest local office of the Administration?

An accredited person must inform the nearest local office of the Administration whenever a vessel is initially certificated under these regulations and a register in the prescribed form has been issued, as stated in 1919.11(e).

  • Notify the local office promptly after initial certification and issuance of the register.
  • The standard does not prescribe a specific notification format; use whatever method (mail, email, or other) is accepted by your local OSHA office.

Under 1919.11(f), which certificates must be sent to the nearest local office and in what timeframe?

A copy of each certificate relating to unit tests or thorough examinations—except those issued by the manufacturer and those issued by accredited persons outside the United States—must be sent to the nearest local office of the Administration within 10 days after issuance, as required by 1919.11(f).

  • Do not send certificates issued by the manufacturer or by accredited persons outside the United States.
  • These submitted records become part of the Administration's file on the accredited person.

Under 1919.11(f), do certificates issued by the manufacturer need to be sent to the nearest local office?

No; certificates issued by the manufacturer are explicitly excluded from the requirement to be sent to the nearest local office, according to 1919.11(f).

  • Only certificates for unit tests or thorough examinations issued by accredited persons (and not issued outside the U.S.) must be sent within 10 days.

Under 1919.11(f), do certificates issued by accredited persons outside the United States have to be sent to the nearest local office?

No; certificates issued by accredited persons outside the United States are excluded from the requirement to be sent to the nearest local office, per 1919.11(f).

  • Only certificates issued within the United States by accredited persons (other than manufacturers) must be sent to the local office within 10 days.

Under 1919.11(f), what happens to the certificates that are sent to the nearest local office?

The certificates sent to the nearest local office form a part of the Administration's file on the accredited person, as stated in 1919.11(f).

  • Keep your own copies as well, since the Administration maintains its own file for oversight and recordkeeping.

Under 1919.11(g), what changes must an accredited person promptly notify the nearest local office about?

An accredited person must promptly notify the nearest local office of the Administration about any changes in technical personnel, fee schedules, geographical areas in which operations are conducted, or other pertinent substantial changes in its organization or operations, as required by 1919.11(g).

  • Examples include hiring or losing inspectors/certifiers, changing the fees charged, expanding or reducing service areas, or reorganizing operations that affect certification activities.
  • Prompt notification helps OSHA keep accreditation and contact details up to date.

Under 1919.11, does the standard specify the exact format or method for notifying the nearest local office?

No; the standard requires notification to the nearest local office but does not prescribe a specific format or method for that notification in the text of 1919.11(e) and 1919.11(g).

  • Use a reliable method (written letter, email, or other communications accepted by your local OSHA office) and keep a record of the notification.

Under 1919.11, does the standard set a general record-retention period for the records required in paragraphs (a) and (b)?

The text of 1919.11 does not set a specific overall retention period for the records required in paragraphs (a) and (b); it only requires that certain certificates be sent to the local office and become part of the Administration's file as described in 1919.11(f).

  • Because 1919.11 does not specify retention lengths, maintain records as long as needed to demonstrate compliance and as requested by the Administration; check with the nearest local OSHA office for guidance on retention expectations.

Under 1919.11(d), does the accredited person who performs work for a vessel have to contact the original register issuer before issuing certificates?

No; 1919.11(d) does not require prior contact, but it does require that when tests or treatments are performed by an accredited person other than the original issuer, the performing accredited person must furnish copies of any certificates issued and information as to register entries to the person who originally issued the register, as stated in 1919.11(d).

  • You can perform the tests and issue certificates, but you must promptly send copies and register information to the original issuer afterward.

Under Part 1919 generally and the 1977 Letter of Interpretation, who is responsible for accrediting persons to certificate vessels' cargo gear?

Part 1919 sets the maritime requirements for persons accredited to certificate vessels' cargo gear, and accreditation procedures are governed by OSHA; recognition and accreditation are handled according to Part 1919 as discussed in the Part 1919 overview and clarified in the 1977 Letter of Interpretation about accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

  • The 1977 Letter of Interpretation explains that procedures exist for persons to be recognized as competent/accredited under Part 1919 and that accreditation is tied to the standards in this part.
  • For questions about obtaining or verifying accreditation, consult Part 1919 and contact OSHA's local office for procedural guidance.

Under 1919.11, what should an accredited person do to prepare for an inspection by the Assistant Secretary under 1919.11(c)?

An accredited person should organize and make immediately available the records required by paragraphs (a) and (b), since those records must be available for examination by the Assistant Secretary pursuant to 1919.11(c).

  • Keep files labeled, with copies of certificates, register entries, and status updates.
  • Maintain a clear log of when certifications and tests were performed and who performed them so an inspector can review quickly.

Under 1919.11, are accredited persons required to file records electronically or only in paper form?

1919.11 does not specify whether records must be kept in electronic or paper form; it only requires that the records exist and be available for examination by the Assistant Secretary as stated in 1919.11(c) and that certain certificates be sent to the nearest local office within 10 days under 1919.11(f).

  • Use whichever format ensures accuracy, accessibility, and timely submission to the local office; maintain copies of transmissions for your records.

Under 1919.11, if an accredited person changes the geographical areas where it operates, what is the compliance step required and why?

If an accredited person changes the geographical areas in which it operates, it must promptly notify the nearest local office of the Administration about that change, as required by 1919.11(g).

  • Prompt notification lets OSHA maintain accurate oversight and contact information and ensures that records and accreditation files reflect the accredited person's actual areas of operation.