Safe working load increases

No. Safe working loads must not be increased beyond the manufacturer's ratings or original design limitations unless you meet one of the two conditions stated in 1919.77(a).

• You must have the manufacturer's approval to increase the safe working load, or
• Where the manufacturer's services are not available (including foreign manufacture), an engineering design analysis by, or acceptable to, an accredited certification agency is required and all necessary structural changes must be carried out.

This requirement is set out explicitly in 1919.77(a).

If the manufacturer is not available or will not approve the increase, you must obtain an engineering design analysis that is performed by, or acceptable to, an accredited certification agency and carry out any structural changes the analysis requires. This is required by 1919.77(a).

• The analysis should evaluate the component stresses, factors of safety, and whether the device's original design can safely support the new load.
• If modifications are necessary to meet the increased load, those structural changes must be completed before the increased safe working load is used.

An "accredited certification agency" is an organization or person accredited under Part 1919 to certify material handling devices; the certification must be acceptable under Part 1919. The accreditation framework and the requirement that certification be by persons accredited under Part 1919 are discussed in OSHA guidance such as the "Competent person accreditation procedures" letter of interpretation (April 26, 1977) at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26.

• If you are unsure who is accredited, contact OSHA or consult Part 1919 resources for current accreditation procedures and a list of recognized certification entities.
• The accredited agency must either perform the analysis or accept the analysis by a qualified engineer as meeting Part 1919 criteria, per 1919.77(a).

No. You may not temporarily raise a safe working load beyond the manufacturer's rating unless you have the manufacturer's approval or an engineering design analysis acceptable to an accredited certification agency, as required by 1919.77(a).

• A one-time exception is not provided in the regulation; the standard requires either manufacturer approval or the specified engineering certification.
• Attempting a temporary increase without following these steps could create an unsafe condition and violate Part 1919 requirements.

Yes. If the engineering analysis indicates that structural changes are necessary to support the increased safe working load, those modifications must be completed before the increased rating is used, per 1919.77(a).

• Do not rely solely on calculations: if analysis requires welds, reinforcement, new components, or other changes, perform and inspect those changes prior to use.
• After modifications, the device should be re-evaluated or re-certified by the accredited certification agency as required under Part 1919.

A qualified engineer or an accredited certification agency may perform the engineering design analysis, but the analysis must be acceptable to the accredited certification agency when the manufacturer is not available, according to 1919.77(a).

• Many employers use a licensed professional engineer experienced in marine material handling equipment to perform the analysis.
• The analysis may also be prepared by in-house engineering staff, but it must be reviewed and accepted by the accredited certification agency if the agency is the required acceptor under Part 1919 (see the OSHA interpretation on accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).

No—the rule applies the same: equipment of foreign manufacture requires engineering design analysis by, or acceptable to, an accredited certification agency if the manufacturer's services are not available, per 1919.77(a).

• The regulation explicitly mentions foreign-manufactured equipment as a case where accredited-agency analysis is required when the manufacturer cannot provide approval.
• The accredited agency must determine whether the foreign design can safely support the proposed increase and require structural changes as needed.

Yes. When safe working loads are increased or structural changes are made, the device must be certified in accordance with Part 1919 by persons accredited under Part 1919; certification ensures the device meets applicable safety criteria (see Part 1919 and the requirement in 1919.77(a)).

• OSHA guidance notes that certain maritime material handling devices must be certificated by persons accredited under Part 1919 (see the OSHA interpretation on accreditation procedures at https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).
• Keep documentation of the certification and any engineering analyses as part of your compliance records.

Yes. The prohibition on increasing safe working loads beyond the manufacturer's rating or original design applies to material handling devices covered by Part 1919, which includes shore-based material handling devices and their components where Part 1919 applies; you must follow 1919.77(a).

• If the component (sling, chain, rope) is governed by Part 1919 certification requirements, any intended increase in its working load requires manufacturer approval or an acceptable engineering analysis and any necessary structural changes.
• For clarity on whether a specific item is within the maritime Part 1919 scope, see Part 1919 and related OSHA guidance.

Only if the engineering design analysis performed by the in-house engineer is accepted by the accredited certification agency when the manufacturer's approval is not available; 1919.77(a) requires the analysis to be performed by, or acceptable to, an accredited certification agency.

• In-house analyses may be acceptable, but the accredited certification agency must review and accept them as meeting Part 1919 criteria if the manufacturer cannot provide approval.
• Employers should coordinate with the accredited agency early to confirm the scope and documentation the agency will require for acceptance.

No. Load tests alone are not sufficient; increases must be based on the manufacturer's approval or on an engineering design analysis that is acceptable to an accredited certification agency, as required by 1919.77(a).

• Load tests can be part of the verification and validation process, but they do not replace the required engineering analysis or the need for accredited acceptance.
• If the engineering analysis requires structural changes, those must be made and then tested and certified by the accredited agency.

You should keep the engineering design analysis, any correspondence or approval from the accredited certification agency (or the manufacturer), records of structural changes made, and the re-certification documentation required under Part 1919. This follows the compliance and certification expectations implicit in 1919.77(a).

• Maintain the analysis report showing calculations, assumptions, and conclusions.
• Keep records of inspections, modifications, welding or machining work, test results, and final certification by the accredited agency.
• Retain these records for the period required by Part 1919 and make them available during inspections.

Before increasing a safe working load, the ship operator should (1) seek the manufacturer's approval, and if that is not available, (2) obtain an engineering design analysis by or acceptable to an accredited certification agency, carry out any required structural changes, and obtain re-certification under Part 1919, as required by 1919.77(a).

Suggested checklist:

• Request written approval from the manufacturer.
• If manufacturer approval is not available, retain a qualified engineer to prepare an analysis acceptable to an accredited certification agency.
• Complete any structural modifications indicated by the analysis.
• Have the accredited certification agency inspect, test, and certify the modified device.
• File and retain all documentation, analyses, and certifications under Part 1919.

Part 1919 applies to maritime (shore-based) material handling devices as established by the Part itself, so whether Part 1919 applies depends on the device and workplace; the general Part 1919 scope and its application are described at Part 1919. OSHA has also explained in other guidance that applicability of various standards can depend on workplace circumstances (see the interpretation on applicability dated February 19, 1991 at https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

• Confirm that the device and operation fall under Part 1919's shore-based material handling coverage.
• If in doubt, consult OSHA or the applicable regional office to confirm whether Part 1919 requirements, including certification and the limits on increasing safe working loads in 1919.77(a), apply to your equipment.