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OSHA 1919.19

Welded gear certification requirements

Subpart D

14 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.19, does any chain or cargo gear welded for repair have to be heat treated?

Yes — chains or other gear lengthened, altered, or repaired by welding must be properly heat treated when heat treatment is necessary. The regulation states that welded repairs "shall be properly heat treated where necessary," and must then be tested and reexamined before return to service (1919.19).

Under 1919.19, what must be done before welded cargo gear is used again?

Before being put back into service, welded chains or gear must be tested and reexamined in the manner set forth in Subpart E of Part 1919. The rule explicitly requires testing and reexamination following welding repairs, so do not return gear to service until those examinations required by Subpart E have been completed (1919.19).

Under 1919.19, how do I know when heat treatment is "necessary" after welding a link or other gear?

Heat treatment is required when welding could change the metal properties in a way that affects strength, hardness, or toughness, so you must heat treat whenever metallurgy or the manufacturer's guidance indicate it's needed. The regulation uses the phrase "where necessary," which means determine necessity based on the material, type of repair, and applicable engineering or manufacturer's recommendations, then follow the testing/reexamination requirements in Subpart E before reuse (1919.19). Employers should rely on qualified technical judgment (for example, a competent person or metallurgist) to make that determination; OSHA has advised that employers assign competent persons to identify hazards and ensure corrective measures (Competent person guidance).

Under 1919.19, who should perform the testing and reexamination after welding repairs?

Testing and reexamination should be carried out by persons qualified to perform the required inspections and tests, such as certified inspectors, competent persons, or organizations qualified by experience and training. The standard requires the tests and reexamination "in the manner set forth in Subpart E," so the employer must ensure the personnel performing those duties meet the qualifications called for by Subpart E and by the employer's safety program (1919.19; see OSHA guidance that employers assign a competent person to identify hazards and take corrective measures (Competent person guidance).

Under 1919.19, what specific tests are required after welding a chain or other cargo gear?

The standard requires testing and reexamination "in the manner set forth in Subpart E of this part," so you must follow Subpart E to know the exact tests required. In practice, Subpart E prescribes the inspection and proof-load or nondestructive testing requirements applicable to cargo gear; therefore consult Subpart E of Part 1919 for the detailed testing procedures and acceptance criteria before returning welded gear to service (1919.19).

Under 1919.19, does lengthening chain by welding (adding links) trigger the repair requirements?

Yes — lengthening, altering, or repairing chain by welding falls squarely under 1919.19 and therefore requires any necessary heat treatment and testing/reexamination per Subpart E before the gear is used again. The regulation explicitly includes "lengthened" gear in its scope (1919.19).

Under 1919.19, can I use welded cargo gear temporarily while waiting for official testing?

No — you must not return welded or altered gear to use until it has been properly heat treated where necessary and tested and reexamined as required by Subpart E. The rule requires those steps to be completed "before again being put into use" (1919.19).

Under 1919.19, may repairs or welding be performed by an outside shop, and is the employer still responsible?

Yes — welding repairs can be performed by an outside shop, but the employer remains responsible for ensuring the work meets 1919.19 (proper heat treatment where necessary) and the Subpart E testing/reexamination before returning gear to service. The employer must ensure the outside work follows the required procedures and is verified through the required tests and inspections (1919.19).

Under 1919.19, should I keep records of welding repairs and subsequent tests for cargo gear?

Yes — while 1919.19 directs that welded gear be heat treated when necessary and tested/reexamined per Subpart E, you should retain records of repairs, heat-treatment steps, and the required tests to demonstrate compliance and the safety of the gear. Maintaining documentation helps show that you followed the required reexamination and testing procedures and meets the employer's obligation to provide a safe workplace under OSHA principles (1919.19; see OSHA guidance on employer responsibility for identifying hazards and corrective measures (Applicability guidance)).

Under 1919.19, does it matter whether welding repair is done in the field or at a certified shop?

No — the location of the welding does not change the requirement: whether repaired in the field or in a shop, welded gear that has been lengthened, altered, or repaired must be heat treated where necessary and tested/reexamined in accordance with Subpart E before being used again (1919.19).

Under 1919.19, does the rule require use of a qualified welder for gear repairs?

The text of 1919.19 does not specify welder certification, but it requires proper heat treatment where necessary and testing/reexamination before reuse, which in practice means repairs should be done by personnel qualified to perform safe, code-compliant welding. Employers must ensure welding and subsequent testing meet applicable standards and that competent persons oversee the work (1919.19; OSHA guidance recommends assigning competent persons to identify hazards and ensure corrective measures (Competent person guidance).

Under 1919.19, does repairing a hoist or block by welding trigger the same requirements as repairing a chain?

Yes — the provision covers "chains or other gear" that have been lengthened, altered, or repaired by welding, so welded repairs to hoists, blocks, or other cargo gear must be heat treated where necessary and tested/reexamined per Subpart E before they can be used again (1919.19).

Under 1919.19, what is Subpart E and where do I find the testing details referenced in 1919.19?

Subpart E of Part 1919 contains the testing and examination procedures for cargo gear that 1919.19 refers to; you must consult Subpart E of Part 1919 to get the specific inspection, proof-load, and acceptance criteria. For the scope and cross-reference, see Part 1919 and the 1919.19 requirement that directs you to Subpart E (Part 1919 overview; 1919.19).

Under 1919.19, who is ultimately responsible for ensuring welded gear is safe to return to service?

The employer is ultimately responsible for ensuring welded gear is properly heat treated where necessary and tested/reexamined per Subpart E before returning it to service. Employers must ensure competent personnel perform or verify the work and that required inspections and tests are completed to comply with 1919.19 (1919.19; OSHA guidance emphasizes the employer's role in assigning competent persons to identify hazards and take corrective measures (Competent person guidance).