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OSHA 1919.34

Proof tests after repairs

Subpart E

17 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.34, when must an assembled gear be examined after repairs or alterations?

Under 1919.34, an assembled gear must be examined whenever proof loads are applied after repairs or alterations. The rule states that “when proof loads are applied after repairs or alterations, all parts of the assembled gear shall be examined” and directs you to the examination requirements in 1919.30, 1919.31(c), or 1919.32(c), whichever is applicable. See 1919.34 for the requirement.

Under 1919.34, which inspection criteria apply after proof loads are applied: 1919.30, 1919.31(c), or 1919.32(c)?

Under 1919.34, you must apply the examination criteria from whichever section—1919.30, 1919.31(c), or 1919.32(c)—is applicable to the type of gear being tested. 1919.34 requires that all parts of the assembled gear be examined “as required in” the applicable one of those sections, so you must use the specific inspection steps and acceptance criteria set out in the section that covers your gear. See 1919.34.

Under 1919.34, which parts of the gear must be examined after a proof load following a repair or alteration?

Under 1919.34, all parts of the assembled gear must be examined after a proof load following a repair or alteration. The standard explicitly requires examination of “all parts of the assembled gear” and refers you to the detailed inspection requirements in 1919.30, 1919.31(c), or 1919.32(c), as applicable to the gear type. See 1919.34.

Under 1919.34, if a repair seems minor, do I still need to examine all assembled gear parts when a proof load is applied?

Yes. Under 1919.34, the size or apparent severity of the repair does not change the requirement: when a proof load is applied after repairs or alterations, all parts of the assembled gear must be examined as required in 1919.30, 1919.31(c), or 1919.32(c), whichever applies. The standard places emphasis on examining the full assembled gear after any proof-load application following repairs/alterations.

Under 1919.34, who may perform the required examinations after proof loads—does the examiner need to be a 'competent person' or have a special accreditation?

Under 1919.34, examinations must meet the requirements in the applicable inspection section; the person performing those examinations should be competent to identify hazards and assess the equipment. OSHA has long stated that the employer assigns or approves the "competent person" and that a competent person must be capable of identifying hazards and authorized to correct them (see the 1977 interpretation on competent person accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26). In some maritime situations covered by Part 1919, certification or accreditation of persons who examine or certify certain material-handling devices may be required; the 1977 interpretation explains that requirement and the employer’s role. See 1919.34 and https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26 for more on competent person and accreditation considerations.

Under 1919.34, does the employer remain responsible for examinations after repairs even if an outside vendor performed the repair and proof test?

Yes. Under 1919.34, the requirement to examine all parts of the assembled gear when proof loads are applied after repairs or alterations applies regardless of who performed the repair. Employers retain responsibility to ensure the examination is completed in accordance with the applicable inspection provisions (1919.30, 1919.31(c), or 1919.32(c)). The employer’s duty to provide a safe workplace is a continuing obligation (see OSHA applicability guidance at https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

Under 1919.34, is a routine periodic inspection equivalent to the post-repair examination required when proof loads are applied?

No. Under 1919.34, the post-repair examination required when proof loads are applied is distinct from routine periodic inspections; 1919.34 specifically requires examination of all parts of the assembled gear following any proof-load application after repairs or alterations, using the criteria in 1919.30, 1919.31(c), or 1919.32(c). Routine inspections serve ongoing maintenance and hazard identification, but 1919.34 creates a specific post-proof-load inspection obligation tied to repairs/alterations.

Under 1919.34, does the standard define what a "proof load" is and how it must be applied?

No. 1919.34 requires examination when proof loads are applied after repairs or alterations, but the text of 1919.34 itself does not define the term "proof load" or specify detailed test procedures. To determine the appropriate proof-load magnitude and application method you should consult the applicable equipment-specific sections (1919.30, 1919.31(c), 1919.32(c)), manufacturer instructions, and recognized industry practices. See 1919.34.

Under 1919.34, if only one component of an assembled gear is repaired, do I still need to examine the other components after applying a proof load?

Yes. Under 1919.34, the rule is explicit: when proof loads are applied after repairs or alterations, all parts of the assembled gear must be examined as required in the applicable inspection section (1919.30, 1919.31(c), or 1919.32(c)). Even when only a single component is repaired, the assembled gear must be examined as required.

Under 1919.34, does the standard require employers to keep records of the post-repair proof-load examinations?

Section 1919.34 itself does not explicitly state recordkeeping requirements for post-repair proof-load examinations; it requires that all parts be examined when proof loads are applied after repairs or alterations and refers you to the applicable inspection sections (1919.30, 1919.31(c), or 1919.32(c)). To determine whether specific recordkeeping is required, consult those applicable sections and any other Part 1919 provisions or employer policies that address documentation and certification.

Under 1919.34, does the post-repair examination have to be visual only, or can it include non‑destructive testing and measurements?

Under 1919.34, the examination required after proof loads must meet the criteria in the applicable section (1919.30, 1919.31(c), or 1919.32(c)). Those sections set the scope of the examination; they may require visual inspection, measurements, functional checks, or other tests as appropriate for the gear. Therefore, the post-repair examination is not limited to visual inspection if the applicable section or manufacturer’s guidance requires or permits other test methods. See 1919.34 and the referenced inspection sections.

Under 1919.34, are there situations where the person performing the post-repair proof test must be officially accredited by OSHA?

Sometimes. 1919.34 requires examinations after proof loads but does not itself mandate OSHA accreditation of examiners. However, OSHA’s earlier guidance explains that in certain maritime situations covered by Part 1919, material-handling devices must be certificated by persons then currently accredited by OSHA as provided in Part 1919; see the 1977 interpretation on competent person accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26. Employers should review the specific Part 1919 provisions applicable to their equipment and, where accreditation or certification is required, ensure the examiner meets that requirement.

Under 1919.34, how do I decide whether to use the inspection steps in 1919.30, 1919.31(c), or 1919.32(c)?

Under 1919.34, you must use the inspection steps in the section that applies to the type of gear being examined: 1919.30, 1919.31(c), or 1919.32(c). The appropriate section is determined by the specific gear category (for example, the type of certificate, device, or assembly) addressed by each section; consult those sections directly to identify which one covers your equipment and to follow the specified examination requirements. See 1919.34.

Under 1919.34, are alterations that do not affect load-bearing parts exempt from the requirement to examine all parts after a proof load is applied?

No. 1919.34 does not provide an exemption for alterations that appear not to affect load-bearing parts; it states that when proof loads are applied after repairs or alterations, all parts of the assembled gear shall be examined according to the applicable inspection section. If you apply a proof load after any repair or alteration, you must examine the assembled gear per the referenced requirements.

Under 1919.34, must proof loads be applied to the gear while it is assembled, or can parts be proof-tested separately?

Under 1919.34, the provision addresses proof loads applied after repairs or alterations to the assembled gear and requires that all parts of the assembled gear be examined. This emphasizes inspection of the assembled system after a proof-load application; whether individual parts may also be proof-tested separately depends on the applicable inspection section (1919.30, 1919.31(c), or 1919.32(c)) and manufacturer guidance. In short, 1919.34 requires assembled-gear examination after proof-load application; separate part testing may be supplemental but does not replace the assembled-gear examination required by 1919.34.

Under 1919.34, how often must proof tests be performed after repairs or alterations?

Under 1919.34, a proof test is required when proof loads are applied after repairs or alterations; 1919.34 does not set recurring intervals for proof tests. In other words, the requirement is event-driven: when repairs or alterations occur and a proof load is applied afterward, the assembled gear must be examined according to the applicable inspection section (1919.30, 1919.31(c), or 1919.32(c)). For routine intervals and other testing schedules, consult those sections and manufacturer or industry guidance.

Under 1919.34, if no proof load is applied after a repair, does 1919.34 still require an examination?

No, not specifically under 1919.34 itself. 1919.34 applies when proof loads are applied after repairs or alterations, requiring an examination in that circumstance. If no proof load is applied, 1919.34 does not impose that post-proof-load examination; however, other inspection or maintenance requirements in 1919.30, 1919.31(c), or 1919.32(c) or employer policies may still require inspection after repairs even without a proof-load application.