Crane load determination without data

Under 1919.75(a), the owner is the party who assigns the safe working load ratings based on the owner's information and warranty that those ratings are correct.

• Unit test certificates for that device must state the basis for any SWL assignment, so the owner's information/warranty and any supporting evidence should be documented on the certificate.

Cited authority: 1919.75(a).

The unit test certificate must state the basis for the safe working load assignment—meaning it should identify the owner's information and warranty or any tests, calculations, or references used to set the SWL.

• Practically, include who provided the load value (the owner), the form of the owner's warranty (written statement or test report), date of assignment, and any testing or inspection evidence used to justify the rating.

Cited authority: 1919.75(a).

Yes—an owner's SWL assignment can be based on third-party inspection or test reports, but the unit test certificate must state that basis and identify the supporting reports or inspector.

• Document the third party's name, credentials or accreditation (if any), the test method used, dates, and the owner’s warranty that the assigned rating is correct.
• If the certification was performed by a person accredited for Part 1919 work, record that accreditation on the certificate as well.

Cited authority: 1919.75(a); see also OSHA's discussion that certain maritime devices must be certificated by persons accredited under Part 1919, 1977-04-26 letter of interpretation.

The standard does not prescribe that the owner's warranty be verbal or written, but because 1919.75(a) requires that the unit test certificate state the basis for any SWL assignment, it is best practice—and strongly recommended—to have the owner's warranty documented in writing and attached or summarized on the unit test certificate.

• Written documentation provides clear evidence during inspections and helps protect employers and workers by showing the factual basis for the assigned rating.

Cited authority: 1919.75(a).

The employer is responsible for providing a safe workplace and must not rely on an unsafe SWL; employers must act to protect workers if an owner's assigned rating is suspected to be incorrect.

• OSHA enforces workplace safety under specific standards and the general duty to provide a workplace free from recognized hazards; if the owner's warranty appears unreliable, the employer should remove the equipment from service or obtain testing/certification by a competent or accredited person.

Cited authority: 1919.75(a) and OSHA's general obligations discussed in the 1991-02-19 letter of interpretation (employer obligation to address hazards when no standard covers the exact circumstance).

The rule does not explicitly require a physical load test, but if the SWL will be assigned without manufacturer's data, the basis for that assignment (which can include physical tests) must be stated on the unit test certificate.

• Because safety depends on accurate ratings, many employers choose to perform load tests, engineering calculations, or inspections and document those results on the unit test certificate to support the owner's warranty.
• When certification is required by maritime rules, qualified or accredited persons often perform such tests—see the discussion in OSHA's 1977-04-26 letter of interpretation.

Cited authority: 1919.75(a); 1977-04-26 letter.

Keep the unit test certificate that states the basis for the SWL assignment and any supporting documents such as the owner's written warranty, inspection reports, test reports, calculations, and the identity/credentials of any person who performed the evaluation.

• These records should be retained and made available for OSHA inspection to demonstrate how the SWL was determined.

Cited authority: 1919.75(a).

Yes—an owner may base an SWL assignment on information from an identical machine, but the unit test certificate must state that basis and document how the machines are equivalent.

• Document model numbers, serial numbers, evidence that the machines are identical in configuration and condition, and any inspection or testing performed to confirm equivalence. If specialized certification is required by maritime rules, use an accredited certifier and record that on the certificate.

Cited authority: 1919.75(a); see also the accreditation discussion in the 1977-04-26 letter.

A competent person or an OSHA-accredited certifier can evaluate equipment, perform tests or inspections, and produce the supporting documentation that the owner can rely on when assigning an SWL; their findings should be recorded on the unit test certificate.

• OSHA has explained that employers assign or approve a "competent person," and that certain maritime material-handling devices must be certificated by persons accredited under Part 1919—so use qualified evaluators and document their credentials.

Cited authority: 1919.75(a) and OSHA's 1977-04-26 letter of interpretation regarding competent persons and accreditation for Part 1919 certifications.

If manufacturer's or design data are not available after modification, the owner may assign an SWL, but the modification and the basis for the assigned rating (inspection, calculations, tests) must be documented on the unit test certificate and supported by a competent or accredited evaluator if necessary.

• Modifications increase uncertainty; to protect workers, obtain written documentation of the modification, engineering evaluations or tests, and credentials of the person(s) who performed the assessment, then put the updated basis on the unit test certificate.

Cited authority: 1919.75(a) and OSHA guidance on certificating maritime devices in the 1977-04-26 letter.

Operator experience or historical practice can be part of the owner's information used to assign an SWL, but the unit test certificate must clearly state that the rating is based on that owner-provided information and warranty, and it is safer to supplement experience with inspections, calculations, or tests.

• Relying solely on informal practice increases risk; document who provided the information, why it is credible, and any corroborating evidence.

Cited authority: 1919.75(a).

Provide the unit test certificate that states the basis for the SWL assignment along with supporting documents such as the owner's warranty, inspection and test reports, calculations, and the credentials of any certifier.

• Keep these records organized and readily available for inspection so OSHA can verify the basis for the assigned ratings.

Cited authority: 1919.75(a).

If manufacturer's or design data later become available and conflict with the owner's assigned SWL, the employer should reassess the SWL immediately and update the unit test certificate to reflect the correct basis—following the manufacturer's data where it is reliable—and take corrective steps to protect workers until the issue is resolved.

• Document the change, the reasons for updating the rating, and any interim work restrictions or inspections performed.

Cited authority: 1919.75(a) and the employer obligation to address hazards as described in the 1991-02-19 letter of interpretation.