Grace periods for gear certification

Under 1919.18(a), annual or six-month certification requirements must be completed by the end of the voyage during which they become due.

• Practical tip: if a required annual or six-month inspection becomes due while the ship is on a particular voyage, you may meet the requirement by completing the certification before that voyage ends.

(See the text of 1919.18(a).)

Under 1919.18(b), quinquennial requirements must be completed within six months after the date when they become due.

• Practical tip: plan scheduling so quinquennial (every five-year) certifications are arranged shortly before or within six months after their due date to stay compliant.

(See the text of 1919.18(b).)

Under 1919.18(c), no—grace periods shall not be deemed to extend subsequent due dates.

• That means if you use a grace period to delay a certification, the next scheduled due date is calculated from the original cycle, not from the delayed completion date.

(See the text of 1919.18(c).)

Under 1919.18(a), the latest time is the end of the voyage during which the inspection became due.

• Example: if an annual inspection becomes due three days after sailing, you must complete that inspection before that same voyage ends to meet the regulation.

(See 1919.18(a).)

Yes. Under 1919.18(b), you may complete quinquennial requirements within six months after the date when they become due, so completing them after returning to port within that six-month window meets the timing requirement.

• Practical reminder: arrange ports or contractors so the certification is done within that six-month window.

(See 1919.18(b).)

No. Under 1919.18(c), using a grace period does not change or extend subsequently scheduled due dates.

• In practice, after completing a delayed certification, you must still track future due dates based on the original certification cycle unless another provision specifies otherwise.

(See 1919.18(c).)

Under 1919.18(b), a 'quinquennial requirement' refers to a requirement that recurs every five years and must be completed within six months after it becomes due.

• Practical note: quinquennial usually applies to five-year surveys or certifications required by the subpart.

(See 1919.18(b).)

Yes. Under 1919.18(a), the deadline for annual or six-month requirements is the end of the voyage during which they become due, so if they become due before or during that voyage you may complete them by voyage end.

• Practical application: schedule the inspection to occur before your voyage returns or ends so you remain within the specified grace period.

(See 1919.18(a).)

Under 1919.18, completing the certification within the permitted grace period satisfies the subpart's timing requirement; the text does not explicitly address enforcement actions or interim inspection status.

• Practical note: although the rule authorizes a grace period, employers should document scheduling and completion and be prepared to explain timing to OSHA inspectors if asked.

(See 1919.18.)

Under 1919.18, employers should schedule annual/six-month certifications to be done by the end of the voyage during which they become due and schedule quinquennial certifications to be completed within six months after their due date.

• Suggested steps:
  • Track original due dates for annual, six-month, and quinquennial items.
  • Book inspections before voyage end (for annual/six-month) or within six months (for quinquennial).
  • Keep clear records of when a requirement became due and when it was completed.

(See 1919.18(a) and 1919.18(b).)

Under 1919.18, using an allowed grace period does not change subsequent due dates per 1919.18(c), so you should record the actual completion date but track future due dates based on the original schedule.

• Recordkeeping tips: keep the original due date, the actual completion date, and a note that the completion occurred within the applicable grace period.

(See 1919.18(c).)