Nondestructive examination procedures

Yes — NDE may be used whenever an accredited person or their authorized representative considers it necessary and when it is practical and advisable to avoid disassembly, removal of pins, or similar teardown. This requirement appears in 1919.78(a).

• Use NDE when the accredited examiner judges that meaningful inspection can be done without taking parts apart.
• If NDE cannot access the areas of concern, disassembly may still be required.

(See the Nondestructive examination provision in 1919.78(a).)

Direct answer: 1919.78(a) explicitly allows "electronic, ultrasonic, or other nondestructive methods" to examine structure or parts when appropriate. The text is in 1919.78(a).

• "Electronic" and "ultrasonic" are named examples; the phrase "other nondestructive methods" allows additional NDE techniques (for example, magnetic particle, dye penetrant, radiography, eddy-current), provided the chosen method and procedure are acceptable for the purpose.

(Refer to 1919.78(a) for the regulatory language.)

The NDE procedure must be acceptable to the Assistant Secretary to be used in place of disassembly. This acceptance requirement is stated in 1919.78(a).

• Before using a nonstandard procedure in lieu of disassembly, ensure that the documented method and criteria meet the Assistant Secretary's acceptance.
• If you are unsure how to obtain acceptance, contact OSHA for guidance and follow the application process the agency provides for review of alternate procedures.

(See regulatory language at 1919.78(a).)

Only a person who is accredited or otherwise acceptable to the Assistant Secretary may carry out the NDE. This requirement is stated in 1919.78(a).

• The standard requires that the person performing the test be accredited or acceptable to the Assistant Secretary for that purpose.
• If you have questions about who qualifies or how accreditation is obtained, see OSHA guidance about accreditation and certification under Part 1919 and related interpretations such as the 1977 Letter on competent person accreditation procedures.

It means the NDE must be performed by someone who has been accredited under the Part 1919 accreditation processes or by a person the Assistant Secretary has specifically found acceptable for that task. The phrase comes from 1919.78(a).

• OSHA has historically required accreditation or acceptance for persons certifying certain material handling devices; see the 1977 Letter on competent person accreditation procedures which explains the role of accredited or competent persons under Part 1919.
• If you are unsure whether someone meets the standard, consult OSHA or review Part 1919 accreditation rules and any regional guidance on acceptable qualifications.

(See 1919.78(a) and the 1977 LOI for context.)

Yes — an employer can use an in-house NDE technician only if that person is accredited or otherwise acceptable to the Assistant Secretary for the purpose. This requirement is in 1919.78(a).

• Employers must ensure the in-house person meets the accreditation or acceptability criteria; the employer assigns or approves competent persons in many OSHA contexts (see the 1977 Letter on competent person accreditation procedures).
• If the in-house technician is not accredited or acceptable to the Assistant Secretary, use an accredited outside examiner.

(See 1919.78(a) and the 1977 LOI.)

Yes — 1919.78(a) allows examinations to be carried out without removal of pins or similar parts when the accredited person determines it is practical and advisable to avoid removal. The regulatory text is in 1919.78(a).

• Use NDE on pins/fasteners when the chosen method can reliably evaluate condition in place.
• If the NDE cannot access the critical surfaces or produce conclusive results, removal for direct inspection or additional testing may still be required.

(Refer to 1919.78(a).)

An accredited NDE person should consider whether an in-place nondestructive method will provide reliable, conclusive information and whether avoiding disassembly is practical and advisable; this is the decision standard in 1919.78(a).

Key considerations:

• Accessibility of the area to be inspected and whether the chosen NDE method can detect the defects of concern.
• Safety and feasibility of performing the test without disassembly.
• The necessity of conclusive results for continued safe operation; if results are inconclusive, disassembly or alternate tests may be required.

(See 1919.78(a).)

Direct answer: Paragraph (a) itself does not spell out recordkeeping requirements; it requires that NDE procedures be acceptable to the Assistant Secretary and be performed by an accredited or acceptable person. See 1919.78(a).

• While 1919.78(a) does not list records to keep, good practice is to retain the NDE procedure documentation, qualification/accreditation credentials for the examiner, and the inspection reports for the device certification record.
• For formal requirements about certification and accreditation processes under Part 1919, consult Part 1919 and related OSHA guidance such as the 1977 Letter on competent person accreditation procedures.

(See 1919.78(a) and Part 1919.)

No — the paragraph does not require the Assistant Secretary to be personally involved in each decision; it requires that the procedure followed be acceptable to the Assistant Secretary and that the examiner be accredited or acceptable to the Assistant Secretary. This is stated in 1919.78(a).

• In practice, an accredited person or an accredited program approved under Part 1919 will carry out or approve routine NDE work, and the agency’s acceptance applies to the procedures and qualifications rather than requiring case-by-case direct intervention by the Assistant Secretary.
• For questions about what constitutes an acceptable procedure or acceptable accreditation, consult OSHA or review Part 1919 accreditation guidance such as the 1977 LOI on accreditation procedures.

(See 1919.78(a).)

This nondestructive examination rule applies to certification of shore-based material handling devices covered by Part 1919, Subpart H; the provision is in the 1919.78 heading and its paragraph (a). See Part 1919 for the broader context.

• The requirement is written for shore-based material handling devices (Subpart H) that require certification and periodic examination.
• If you are dealing with such devices, follow the Subpart H certification requirements and apply 1919.78(a) when considering NDE in place of disassembly.

(See Part 1919 and 1919.78(a).)

Possibly — 1919.78(a) requires the NDE to be carried out by an accredited person or someone acceptable to the Assistant Secretary; on-the-job training alone does not automatically meet the accreditation requirement. See 1919.78(a).

• OSHA has advised in other contexts that employers may certify that an employee is trained based on demonstrated proficiency and documented on-the-job training (see the 1996 Letter on qualified employee training requirements).
• For Part 1919 purposes, the person still must meet accreditation or acceptance criteria; if relying on on-the-job training, the employer should document competency and confirm the Assistant Secretary (or OSHA) accepts that person for the particular NDE role.

(See 1919.78(a) and the 1996 LOI on training/qualification concepts.)

No — 1919.78(a) requires that the person be accredited or acceptable to the Assistant Secretary but does not define the accreditation processes in that paragraph. The broader Part 1919 and OSHA program materials govern accreditation. See 1919.78(a) and Part 1919 for context.

• Historical OSHA guidance explains that accreditation and approval processes for competent persons and certifying examiners are handled under Part 1919 procedures (see the 1977 Letter on competent person accreditation procedures).
• For exact accreditation steps, contact OSHA or review the specific accreditation regulations and agency instructions that implement Part 1919 requirements.

(Refer to 1919.78(a) and the 1977 LOI.)

Yes — a procedure acceptable in one workplace might not be acceptable elsewhere because 1919.78(a) requires the procedure to be acceptable to the Assistant Secretary for the specific purpose and circumstances. See 1919.78(a).

• Factors such as the device design, operating loads, safety margins, and the specific defects of concern can affect whether a given NDE method and procedure are sufficient.
• If using a procedure developed elsewhere, document why it is appropriate for your device and be prepared to show acceptance by the Assistant Secretary if requested.

(See 1919.78(a).)

If NDE results are inconclusive, the accredited examiner should recommend further action, which may include disassembly, additional testing, or removal from service until a conclusive determination is made; 1919.78(a) permits NDE in lieu of disassembly only when it provides the needed information and is acceptable to the Assistant Secretary. See 1919.78(a).

• Treat inconclusive findings as a potential safety issue and follow the accredited person’s guidance for repair, more invasive inspection, or taking the device out of service.
• Document the inconclusive results and the follow-up steps, and consult OSHA if there is disagreement about adequacy of inspection or acceptance of alternate procedures.

(See 1919.78(a).)

Yes — the provision allows the accredited person or his authorized representative to decide when nondestructive examination is necessary and practical to avoid disassembly, as stated in 1919.78(a).

• An authorized representative acting under the authority of the accredited person may make the decision, but the representative should be qualified and operating within the scope of the accredited person's authorization.
• The person carrying out the examination still must meet the accreditation or acceptability criteria in the standard.

(See 1919.78(a).)

Yes — OSHA has explained in prior guidance that employers assign or approve competent persons and that certain material handling device certifiers must be accredited under Part 1919; see the 1977 Letter on competent person accreditation procedures and review Part 1919.

• The 1977 letter emphasizes that employers appoint competent persons and identifies that some certifying functions under Part 1919 require persons accredited by OSHA.
• For practical steps, employers should document qualifications, training, and any formal accreditation and confirm acceptance by OSHA when necessary.

(See 1919.78(a) and the 1977 LOI.)

Choose NDE when an accredited examiner determines that nondestructive methods will reliably reveal defects and when avoiding disassembly is practical and advisable; otherwise plan for disassembly. This decision framework comes directly from 1919.78(a).

• Request an accredited inspector to evaluate accessibility, likely defect types, and the reliability of available NDE methods.
• When in doubt about adequacy, prioritize safety: remove components for direct inspection or obtain additional testing until you have conclusive information.

(Refer to 1919.78(a).)

Yes — an employer can rely on a manufacturer-developed NDE procedure provided the procedure is acceptable to the Assistant Secretary and the examiner is accredited or acceptable for the purpose, per 1919.78(a).

• Manufacturer procedures are often appropriate because they consider the device design, but you must ensure the procedure produces reliable, conclusive results for the inspection objective.
• Keep documentation showing why the manufacturer’s procedure is appropriate and that the person performing the NDE is accredited or otherwise acceptable. If necessary, seek OSHA acceptance of the alternate procedure.

(See 1919.78(a).)

Prepare by ensuring the inspection scope and objectives are clear, that the NDE procedure is documented and acceptable, and that the examiner is accredited or acceptable to the Assistant Secretary as required by 1919.78(a).

Recommended steps:

• Assemble device documentation (drawings, service history, prior inspection reports).
• Confirm the NDE method and procedure, and document why it will reliably detect the defects of concern.
• Verify accreditation records or acceptance documentation for the examiner and retain inspection reports.
• If relying on an alternate or novel procedure, be prepared to demonstrate acceptability to OSHA.

(See 1919.78(a) and consult Part 1919 materials at Part 1919.)