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OSHA 1919.35

Order of gear proof tests

Subpart E

9 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.35 (Order of tests), can the loose gear proof-load test be performed after the unit proof-load test?

Yes. Under 1919.35 the loose gear test may be carried out after completion of the unit test when both unit and loose gear proof-load tests are required.

  • This provision only addresses the order when both types of tests are required; it does not change the requirement that both tests be performed when they are otherwise required by the applicable standards.

Reference: Order of tests in 1919.35.

Under 1919.35, am I required to do the loose gear test before the unit test?

No. 1919.35 explicitly allows the loose gear test to be performed after the unit test, so you are not required to do loose gear testing first.

  • The rule provides flexibility in sequencing when both tests are required; it does not force loose gear testing to occur before the unit test.

Reference: 1919.35 Order of tests.

If only loose gear proof-load testing is required (unit testing is not required), does 1919.35 dictate when I must perform the loose gear test?

No. 1919.35 only addresses the order when both unit and loose gear tests are required and does not specify timing when only one type of test is required.

  • If only loose gear testing is required, you must follow the applicable requirements elsewhere in Part 1919 or other applicable standards for timing and procedure; 1919.35 does not add timing rules in that situation.

Reference: 1919.35.

If both unit and loose gear proof-load tests are required, can I delay the loose gear test to a later date after the unit test is completed?

Yes. 1919.35 allows the loose gear test to be carried out after completion of the unit test, so performing the loose gear test later (after the unit test) is permitted.

  • The standard does not set a required interval or deadline for when the loose gear test must follow the unit test; however, you should ensure that any delay still meets other applicable regulatory or safety requirements.

Reference: 1919.35.

Does 1919.35 allow me to skip the loose gear proof-load test if I completed the unit test?

No. 1919.35 does not authorize skipping any required test; it only states that when both unit and loose gear proof-load tests are required, the loose gear test may be performed after the unit test.

  • If regulations or the equipment certification requirements call for both tests, both must be performed; 1919.35 only provides flexibility in sequencing, not elimination of tests.

Reference: 1919.35.

Does 1919.35 specify who must perform the unit or loose gear proof-load tests?

No. 1919.35 only addresses test order and does not specify qualifications or accreditation of the persons performing the tests.

  • If certification or accreditation of testers is required, those requirements appear elsewhere in Part 1919 and related standards; for example, OSHA has noted that material handling devices certificated under Part 1919 may need to be certificated by persons accredited under Part 1919 in certain situations (1977 interpretation on competent person accreditation procedures).

References: 1919.35 and the OSHA interpretation on accreditation (Original URL).

If another OSHA or industry standard specifies a different test sequence, does 1919.35 allow me to use the loose-then-unit order or the unit-then-loose order?

1919.35 permits performing the loose gear test after the unit test when both are required, but it does not repeal or change other specific testing requirements in other standards.

  • If another OSHA standard or an applicable industry requirement prescribes a specific order, you must follow that provision unless Part 1919 explicitly preempts it. Use 1919.35 for allowed sequencing and check the other standard for any conflicting mandatory sequence.

Reference: 1919.35.

Does 1919.35 require written documentation proving that I performed the loose gear test after the unit test?

No. 1919.35 states only that the loose gear test may be carried out after the unit test; it does not include a recordkeeping or documentation requirement about the order.

  • Other sections of Part 1919 or related standards may require records of tests or certifications; consult those provisions for documentation requirements.

Reference: 1919.35.

Where can I find the rule that allows loose gear testing after unit testing and what part of OSHA covers gear certification?

The rule allowing loose gear testing after unit testing is in 1919.35, which is part of OSHA's Part 1919 on Gear Certification. The broader Part 1919 collection of standards addresses certification of vessels, tests and proof loads, heat treatment, and competent persons; see Part 1919 for the full set of related requirements.

  • Use 1919.35 for the specific sequencing allowance, and review other sections in Part 1919 for certification, qualifications, and testing procedures.

References: 1919.35 and Part 1919.