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OSHA 1919.3

Accreditation application requirements

1919 Subpart B

18 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.3(a), where and how must an accreditation application be filed?

Under 1919.3(a) an applicant must file an original and duplicate copy of the accreditation application with the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, Washington, D.C. 20210, using the form provided by OSHA. Each application must be signed and certified by the applicant, and if the applicant is an agency or organization, a responsible officer must sign. See 1919.3(a) for the filing and signature requirement.

Under 1919.3(a), does the application require both an original and a duplicate, and who must sign it?

Under 1919.3(a) the application must include an original and a duplicate copy, and it must be signed and certified by the applicant; if the applicant is an agency or organization, a responsible officer of that agency or organization must also sign. This signature certifies the accuracy of the application information.

Under 1919.3(b)(1), what past work information must I include about types and extent of work?

Under 1919.3(b)(1) you must include a statement describing the types of applicable work you have performed, the amount and extent of that work during the previous three years, representative vessels involved, and representative job orders if available (or equivalent evidence). Provide concrete examples and dates so OSHA can evaluate your recent experience.

Under 1919.3(b)(1), what counts as 'equivalent evidence' if I don't have representative job orders?

Under 1919.3(b)(1) equivalent evidence can include contracts, invoices, survey reports, photos, work logs, or client statements that document the scope, amount, and dates of the work you performed. Provide materials that clearly show the nature and extent of your cargo-gear work over the prior three years so OSHA can verify your experience.

Under 1919.3(b)(2), what details and documentation are required about testing instruments and heat treatment furnaces?

Under 1919.3(b)(2) you must describe any testing instruments and heat treatment furnaces you will use and include test reports that show the instruments meet the accuracy standards in Part 1919. Provide make/model, calibration certificates, calibration dates, calibration procedures, and furnace specifications and certification tests so OSHA can confirm equipment accuracy and suitability.

Under 1919.3(b)(3), must I list every port where I currently do business and where I propose to work?

Under 1919.3(b)(3) you must provide a list of the ports where you currently conduct business as well as the ports where you plan to conduct gear certification activities. Include full port names and locations to make clear the geographic scope of your proposed services.

Under 1919.3(b)(4), what personnel information and resumes must be included in the application?

Under 1919.3(b)(4) you must list your responsible qualified personnel (supervisory and managerial) and any surveyors, and include resumes documenting their experience in testing, examination, inspection, and heat treatment of cargo gear. The list should also identify branch office personnel or surveyors appointed to act for you in U.S. ports.

Under 1919.3(b)(4), what can I do if I have a very large number of personnel and submitting individual resumes would be burdensome?

Under 1919.3(b)(4) if submitting many individual resumes is unduly burdensome you may state that fact and instead submit a list of personnel together with a detailed statement of the qualifications and criteria used to appoint surveyors. This summary must clearly explain how your appointments ensure qualified surveyors are used.

How does OSHA view the employer's role in designating a 'competent person' for certification tasks related to Part 1919?

Under the competent-person interpretation, the employer assigns or approves a 'competent person' and must ensure that person can identify hazards and take corrective action; some maritime material-handling devices must be certificated by persons accredited under Part 1919. See the 1977 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26 for guidance and 1919 for accreditation context.

Under 1919.3(b)(5), what should I include in the fee schedule part of the application?

Under 1919.3(b)(5) include a detailed schedule of fees you will charge for each gear certification service (for example: inspection, testing, heat treatment, certification issuance, travel charges). Be specific about units (per hour, per item) and any additional charges so OSHA can assess the reasonableness of your fees.

Under 1919.3(b)(6), what types of documents can serve as 'evidence of financial stability'?

Under 1919.3(b)(6) acceptable evidence of financial stability can include audited financial statements, bank references or letters, lines-of-credit, balance sheets, profit-and-loss statements, or other reliable financial documentation that demonstrates your ability to sustain operations and fulfill certification commitments.

Under 1919.3(b)(7), what should I provide for business references and how many are required?

Under 1919.3(b)(7) you must provide names of at least three business references who can furnish information about work you have performed. Include each reference's company name, contact person, phone number, email, and a brief description of the work they can confirm.

Under 1919.3(b)(8), what kind of 'additional information' might strengthen my application?

Under 1919.3(b)(8) useful additional information can include quality-control procedures, internal training programs, accreditation or certification from other bodies, equipment maintenance logs, insurance certificates, or written safety policies—anything that helps show your competence and reliability.

Does 1919.3 specify the form to use for applications and where to get it?

Under 1919.3(a) the application must be filed on a form provided by the Administration (OSHA). Contact OSHA or visit the OSHA website for the current application form and filing instructions as required by 1919.3(a).

Can on-the-job experience and employer certification be used to document personnel qualifications under 1919.3(b)(4)?

Yes. Under 1919.3(b)(4) resumes documenting on-the-job experience are acceptable, and consistent with OSHA guidance that employers may certify employees' training or proficiency when records are unavailable (see the training interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1996-03-26-3). Ensure the resumes or employer certifications clearly describe the employee's competence in testing, inspection, and heat treatment tasks.

If my testing instruments are calibrated by a supplier, does 1919.3(b)(2) require I keep the supplier's calibration records?

Under 1919.3(b)(2) you should include test reports or calibration certificates demonstrating that instruments meet the accuracy standards of Part 1919; supplier calibration records are appropriate documentation and should be retained as proof of instrument accuracy and included with the application when available.

Can branch office surveyors act on behalf of the applicant and how must they be documented under 1919.3(b)(4)?

Under 1919.3(b)(4) branch office personnel or surveyors may be appointed to act on the applicant's behalf, but they must be listed in the application and their experience documented—either via individual resumes or, if numerous, via a detailed statement of the qualifications used to appoint surveyors.

Does the application under 1919.3 trigger any federal paperwork control or OMB requirements I should be aware of?

Yes. The information collection in 1919.3 has been approved by the Office of Management and Budget under OMB Control No. 1218–0003, as noted at the end of the section; include complete and accurate information to comply with federal paperwork requirements.