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OSHA 1919.72

Annual crane examination requirements

Subpart H

13 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.72(a), who is allowed to perform the required annual crane examination when no quadrennial unit proof test is due?

An accredited person or that person's authorized representative must perform the required annual examination. This is explicitly stated in 1919.72(a).

Under 1919.72(a), when must the annual crane examination be completed?

The annual examination must be completed not later than the anniversary date of the quadrennial certification for the crane. 1919.72(a) requires the exam "not later than the anniversary date of the quadrennial certification."

  • If you are unsure of the certification anniversary date, refer to the quadrennial certification records for the unit. See Part 1919 for general context.

Under 1919.72(a), what happens in years when a quadrennial unit proof test is required?

Section 1919.72(a) applies only in years when no quadrennial unit proof test is required, so the annual examination requirement described there does not replace or apply in a year when a quadrennial unit proof test is required. See 1919.72(a).

  • For years when a quadrennial unit proof test is due, follow the applicable quadrennial proof-test requirements in Part 1919 and any related certification provisions in 1919.

Under 1919.72(a), what does the annual examination have to conform to?

The annual examination must conform with the requirements of 1919.71(d). 1919.72(a) explicitly links the annual exam to those requirements.

  • Review 1919.71(d) to understand the specific items, testing methods, and documentation that the annual exam must meet.

Under 1919.72(a), may an accredited person delegate the annual examination to an authorized representative, and what should an employer consider when that happens?

Yes. 1919.72(a) allows the annual examination to be carried out by an accredited person or that person's authorized representative.

  • When delegating, the employer should ensure the authorized representative is competent and has the authority to perform the examination and follow the methods required by 1919.71(d). OSHA guidance explains employers assign or approve competent persons and must ensure they are capable of identifying hazards and taking corrective action; see the OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

Under Part 1919, does an "accredited person" performing the annual examination need OSHA accreditation?

Yes—maritime standards in some situations require certification by persons accredited by OSHA as provided in Part 1919. OSHA has stated that certain maritime material-handling device certifications must be performed by persons "then currently accredited by OSHA as provided in Part 1919." See Part 1919 and the employer-competent-person discussion in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

  • Confirm whether your specific equipment and situation requires OSHA accreditation by reviewing Part 1919 and contacting OSHA for clarification if needed.

Under 1919.72(a), how often must you plan for an annual examination for cranes that are not due for quadrennial proof tests?

You must schedule the examination once each calendar year in any year when a quadrennial unit proof test is not required, and it must be completed by the quadrennial certification anniversary date. 1919.72(a).

  • Keep annual scheduling aligned with the unit's quadrennial certification anniversary so you do not miss the required date.

Under 1919.72(a), who is responsible for making sure the annual examination is performed and meets the standard's requirements?

The employer is responsible for ensuring the annual examination is performed by an accredited person or that person's authorized representative and that the examination conforms to 1919.71(d), as required by 1919.72(a).

Under 1919.72(a), if the accredited person is unavailable on the anniversary date, can the employer use another qualified person to meet the deadline?

Yes—1919.72(a) allows the examination to be performed by the accredited person's authorized representative, so an employer can use an authorized or otherwise qualified accredited individual to meet the deadline.

Under 1919.72(a), does the annual examination replace the quadrennial unit proof test?

No. 1919.72(a) applies only in years when no quadrennial unit proof test is required, so it does not replace the quadrennial unit proof test in years when that proof test is due.

Under 1919.72(a), how should an employer document that the annual exam was completed by an accredited person or authorized representative?

Document the examination with dated records that identify who performed the exam (the accredited person or authorized representative), the date it was completed, and that it conforms with 1919.71(d), as required by 1919.72(a).

  • While the specific record elements are detailed in 1919.71(d), good documentation practices include examiner name and credential, findings, corrective actions, and signatures. See Part 1919 for full context.

Under 1919.72(a), what should an employer do if the annual exam uncovers defects or conditions that affect safe operation?

If the annual examination uncovers defects or unsafe conditions, the employer must address and correct those defects before returning the equipment to service, consistent with the requirement that the exam conform to 1919.71(d), as referenced by 1919.72(a).

Under 1919.72(a), can an employer use an in-house employee as the accredited person for the annual examination?

An employer can use an in-house employee only if that person meets the accreditation or qualification required to be an accredited person under Part 1919; otherwise the exam must be performed by someone who holds the required accreditation. See 1919.72(a) and the general Part 1919 provisions at https://www.osha.gov/laws-regs/regulations/standardnumber/1919.

  • OSHA's interpretation on employer-assigned competent persons explains that employers must ensure assigned persons are capable of identifying hazards and authorized to take corrective action; see https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26. If your in-house person is accredited per Part 1919, they can perform the exam.