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OSHA 1919.20

Damaged cargo gear components

Subpart D

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1919.20(a), what must be done when a derrick or associated permanent fitting is found deformed in service between surveys?

You must subject the deformed derrick or permanent fitting to a proof test to determine if it is safe to continue in service. Under 1919.20(a), if the proof test shows the derrick or fitting can remain in service without repair, the existing deformity must be noted on the test certificate. The provision is applied in conjunction with the survey requirements in 1918.51(b).

Under 1919.20(a), what happens if the accredited person considers it unsafe to perform a proof test because of the deformity?

If the accredited person considers the deformity too unsafe to proof test, the derrick or permanent fitting must be repaired or replaced before any proof testing is performed. 1919.20(a) requires repair or replacement in that case, and then the repaired or replaced item must be subjected to proof testing in accordance with Subpart E of Part 1919 before a certificate is issued.

Under 1919.20(b), what must be done if loose gear components are injured or deformed by a proof load?

You must replace any loose gear components that are injured or deformed by a proof load before a certificate is issued. 1919.20(b) clearly requires replacement of injured or deformed loose components prior to certification.

Under 1919.20(c), what are the requirements if a derrick or other fixed installation is damaged by a proof load?

You must replace or repair the injured or deformed derrick/fixed installation and then conduct another proof load test with no resulting damage before issuing a certificate. 1919.20(c) mandates repair or replacement and a successful re-test before certification.

Under 1919.20(a), what must be recorded on the proof test certificate when a proof test indicates continued service is acceptable despite an existing deformity?

You must make a note of the existing deformity on the test certificate. 1919.20(a) requires that a record of the deformity be placed on the certificate if the accredited person permits continued service without repair.

Under 1919.20(b) and (c), can a certificate be issued if a proof test itself causes deformation or injury to gear components or fixed fittings?

No — if the proof test injures or deforms loose components or fixed fittings, those items must be replaced or repaired and the proof test repeated successfully before a certificate can be issued. Both 1919.20(b) and 1919.20(c) require replacement or repair and a subsequent undamaged proof load test prior to certification.

Under 1919.20(b), if a sling hook deforms during proof load but remains attached to the gear, must it still be replaced?

Yes — any loose gear component that is injured or deformed by a proof load must be replaced before certification, regardless of whether it remains attached. 1919.20(b) requires replacement of injured or deformed loose components prior to issuing a certificate. For context on hook safety and latch use (which affects how hooks perform under load), see OSHA's letter on safety latches on sling hooks.

Under 1919.20, are damaged hoisting hooks (latched or unlatched) treated differently after a proof load causes deformation?

No — damaged hooks must be treated like any other injured gear component: if a loose hook is injured or deformed by a proof load it must be replaced before certification, and if a fixed installation or permanent fitting is injured by a proof load it must be repaired or replaced and successfully re-tested. 1919.20(b) and 1919.20(c) apply. For guidance on when latches are useful or expected on hooks, see OSHA’s interpretation on safety latches on sling hooks.

Under 1919.20, who must operate the lifting gear during proof tests — can an operator step away if they become suddenly unable to continue?

The person operating the equipment during a proof test must remain in control and capable of completing the operation; an operator should not leave the controls while a load is suspended. Although 1919.20 governs damage and proof testing, OSHA's interpretation on crane operators makes clear that an operator may not abandon controls while a load is suspended because it creates an unsafe condition (see the crane operator medical condition scenario).

Under 1919.20(a), do proof tests between surveys replace the normal scheduled survey and certification process?

No — a proof test between surveys is a response to a deformity and is used to determine suitability for continued service, not to replace scheduled surveys. 1919.20(a) requires proof testing when deformation is found between surveys and directs notation on the test certificate if continued service is allowed; it does not eliminate the need for the regular survey and certification cycle described elsewhere in Part 1919.

Under 1919.20, if a derrick is repaired after damage during a proof test, what test standard must the repair meet before certification?

The repaired or replaced derrick or fitting must be subjected to a successful proof load test in accordance with the test procedures in Subpart E of Part 1919 before a certificate may be issued. 1919.20(a) and 1919.20(c) require repair/replacement followed by a proof test per the applicable subpart.