Specially designed lifting components

They are not treated as loose gear when they are specially designed as an integral part of a particular lifting unit and are permanently affixed or of such design that two or more components must be tested together. This follows the rule in 1919.32(a).

• Practical implication: if a block or component is built specifically for a single lifting unit and cannot reasonably be tested separately, treat it as part of the lifting unit rather than as removable loose gear subject to separate proof testing under 1919.31.

You may submit design data to an accredited certification agency in place of the loose gear proof test required by 1919.31(a). This is prescribed by 1919.32(b).

• The design data must indicate the design and material specifications and analysis used to determine the designed strength of the specially designed gear.
• The accredited certification agency reviews those data and determines whether the design meets required strength and safety criteria.

The design data should include material specifications, design drawings, and engineering analyses that show how the designed strength is calculated. 1919.32(b) requires submission of design and material specifications and analysis so the designed strength can be determined.

Helpful checklist:

• Material specifications (grade, heat treatment, certifications)
• Detailed drawings and dimensions
• Load calculations and safety factors used
• Stress analysis or finite-element reports, where applicable
• Welding or fabrication procedures and qualifications
• Any relevant test data or prior service history

After the lifting unit is tested as a whole, you must do a thorough visual examination of disassembled parts and perform electronic, ultrasonic, or other equally efficient nondestructive examinations on parts that are not dismantled. This is required by 1919.32(c).

• The visual exam should check for cracks, deformation, corrosion, excessive wear, and other visible defects.
• Nondestructive examination (NDE) methods like ultrasonic testing are needed for components that remain assembled to ensure there are no hidden flaws.

Yes — if a specially designed component is removable and is not permanently affixed or does not require being tested together with other components, it should be considered loose gear and be handled under 1919.31, not as an integral part under 1919.32(a).

• Key test: if the component can be reasonably separated and tested on its own (or is interchangeable among units), treat it as loose gear and follow loose gear proof-test requirements in 1919.31.

The design data must be submitted to an accredited certification agency for review and acceptance, as required by 1919.32(b).

• For guidance on accreditation and competent persons related to Part 1919 certification, see the OSHA letter discussing accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26 which explains that certification under Part 1919 is performed by persons accredited as provided in Part 1919.
• Employers should confirm that the agency they use is recognized/accredited to perform the required certification activities.

The nondestructive examination must be completed after the lifting unit has been tested as a whole — that is, subsequent to the unit test, per 1919.32(c).

• Follow-up NDE ensures parts that were not dismantled are free of hidden flaws that could affect safety in service.

1919.32(c) explicitly allows electronic, ultrasonic, or other equally efficient nondestructive examinations for parts not dismantled.

• Commonly used methods include ultrasonic testing, magnetic particle inspection (where applicable), and radiography if appropriate; choose the method that reliably detects the types of flaws relevant to the component.

No — 1919.32(b) allows submission of design data to an accredited agency instead of the loose gear proof test in 1919.31(a). Additionally, 1919.32(c) requires nondestructive examinations for parts not dismantled.

• In short, destruction of parts is not required by these provisions; engineering data plus NDE and visual inspection are acceptable paths to demonstrate safety.

Engineering analysis and documented design and material specifications may be used in lieu of separate loose gear proof testing, provided those data are submitted to and accepted by an accredited certification agency under 1919.32(b).

• If the accredited agency determines the analysis and data demonstrate adequate designed strength, additional physical proof tests may not be required for the specially designed components treated as integral parts.

Whether components must be tested together is determined by their design as an integral assembly for that particular lifting unit — if two or more components are designed so that they must be tested together, they need not be treated as loose gear under 1919.32(a).

• Practical indicators: components physically interlock, rely on matched tolerances, or have load paths that cross component boundaries such that separate testing would not accurately reflect service conditions.

Employers should keep the accredited agency's certification report and the submitted design data, along with records of the subsequent visual and nondestructive examinations performed after the unit test. 1919.32(b) requires the submission of design data to the accredited agency, and 1919.32(c) requires the post-test inspections.

• Recommended records: design drawings, material certificates, engineering calculations, the accredited agency's acceptance/certification, NDE reports, and visual inspection reports.

The inspections should be performed by qualified personnel competent to recognize defects and to operate the chosen NDE methods; the standard requires the examinations but does not prescribe a specific job title. See 1919.32(c).

• For guidance on accreditation and competent persons in Part 1919 activities, see the OSHA interpretation about competent person accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26 which explains that certification is performed by persons accredited under Part 1919.
• Employers should ensure personnel performing visual and NDE are trained, qualified, and documented as competent for the methods used.

An employer should choose a nondestructive examination method that is capable of reliably detecting the types of flaws of concern in the specific part and that is equivalent in effectiveness to electronic or ultrasonic testing as allowed by 1919.32(c).

• Considerations: the flaw types (cracks, laminations, porosity), material thickness, geometry, and the proven detection capability of the method in that application.
• Document the rationale and qualifications for the chosen NDE method in inspection records.

If the accredited certification agency does not accept the design data, the employer must follow the appropriate proof-test requirements (or otherwise revise the design/data) so that the specially designed gear meets certification criteria; 1919.32(b) requires submission to the accredited agency for determination of designed strength.

• Practical steps: obtain additional testing, revise calculations or materials, or conduct the loose gear proof test required by 1919.31(a) if the agency requires it.