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OSHA 1919.23

Derrick attachment means

Subpart D

12 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.23 (Means of derrick attachment), what basic action is required to protect workers during a derrick test?

You must take steps to keep the foot of the derrick from being accidentally lifted out of its socket or support while the test is performed. The plain requirement is stated in 1919.23.

Under 1919.23 (Means of derrick attachment), who is responsible for making sure the derrick foot is secured during a test?

The employer is responsible for ensuring appropriate measures are taken to prevent the derrick foot from being lifted during the test. The requirement to take such measures is set out in 1919.23, and the employer should designate a qualified or competent person to select and apply those measures as explained in the OSHA interpretation on competent person accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

Under 1919.23 (Means of derrick attachment), who should decide which method or device is "appropriate" to prevent the derrick foot from lifting?

A competent person designated by the employer should decide which securing method or device is appropriate for the specific derrick and test conditions. The plain duty to prevent lifting is in 1919.23, and OSHA guidance on competent persons (how they are assigned and what authority they have) is discussed in the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

Under 1919.23 (Means of derrick attachment), may the employer use temporary blocking, pins, or other devices to keep the derrick foot in its socket during the test?

Yes — temporary blocking, pins, wedges, bolts, or other devices may be used if they effectively prevent the derrick foot from lifting and are judged appropriate by the employer's competent person. The standard requires that "appropriate measures shall be taken" to prevent lifting during the test (1919.23). The selection and application of those devices should be made by a competent person as discussed in the OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

Under 1919.23 (Means of derrick attachment), does the standard itself list specific devices or methods that must be used to secure the derrick foot?

No — 1919.23 does not list specific devices or methods; it requires that appropriate measures be taken to prevent the derrick foot from being lifted during the test. That performance-based requirement appears in 1919.23. The employer must determine what measures are appropriate for the situation, typically using a competent person to make that determination (see the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).

Under 1919.23 (Means of derrick attachment), does the requirement to prevent the foot from lifting apply only to certain types of derricks or to all derricks tested under Part 1919?

The requirement applies to derrick tests covered by Part 1919's gear certification rules; it is part of the Subpart D requirements for vessel cargo gear. The rule is located at 1919.23 and sits within the broader Part 1919 framework at 1919.

Under 1919.23 (Means of derrick attachment), must testing stop immediately if the foot of the derrick begins to lift during a test?

Yes — if the derrick foot starts to lift, the test should be stopped and corrective action taken before continuing. The rule requires that "appropriate measures shall be taken" to prevent accidental lifting during the test (1919.23). OSHA's guidance on competent persons emphasizes that they must have authority to take prompt corrective measures when hazards are found (see https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).

Under 1919.23 (Means of derrick attachment), does the standard require written records or certification specifically because the derrick foot was secured during the test?

No — 1919.23 itself does not require a written record specifically documenting the means used to prevent the derrick foot from lifting. The rule simply requires that appropriate measures be taken during the test (1919.23). However, other parts of Part 1919 or vessel-gear certification procedures may require certification or records for tests generally; consult the overall Part 1919 requirements at 1919 and follow employer policies set by a competent person as described at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

Under 1919.23 (Means of derrick attachment), can the employer rely on manufacturer-supplied sockets, pins, or locks to meet the requirement?

Yes — manufacturer-supplied sockets, pins, locks, or other securing devices may be used if they are suitable to prevent the derrick foot from lifting during the test and are approved by the employer's competent person. The general duty in 1919.23 is to take appropriate measures; the competent person should evaluate and approve any manufacturer-supplied device (see the OSHA interpretation on competent-person duties at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).

Under 1919.23 (Means of derrick attachment), what role does a "competent person" play when securing a derrick foot for a test?

A competent person should assess the hazard, select suitable securing methods or devices, and have the authority to stop the test or take corrective action if a hazard is found. The duty to prevent the foot from lifting is in 1919.23, and OSHA's interpretation about competent persons explains that the employer assigns a competent person who can identify hazards and take prompt corrective measures (https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).

Under 1919.23 (Means of derrick attachment), does the standard apply to tests performed ashore on derricks that will be used on vessels?

Yes — the requirement addresses how a derrick is attached during the test; Part 1919 covers gear certification for vessel cargo gear, which includes testing whether conducted on or off the vessel as part of certification. See 1919.23 and the broader Part 1919 context at 1919.

Under 1919.23 (Means of derrick attachment), what should employers do to prepare before performing a derrick test to meet the standard?

Employers should plan the test, identify hazards, and put in place measures (for example, blocking, pins, lashings, or manufacturer devices) that a competent person has judged will prevent the derrick foot from lifting during the test. The obligation to prevent lifting during the test appears in 1919.23, and OSHA guidance on competent persons supports assigning a person who can identify hazards and order corrective action as needed (https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).