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OSHA 1919.80

Heat treatment requirements

Subpart H

15 Questions & Answers
8 Interpretations

Questions & Answers

Under 1919.80(a), when is heat treatment required for loose gear on shore-based material handling devices?

Yes — heat treatment is required only when the manufacturer recommends it, and it must be done according to the manufacturer's specifications. See 1919.80(a) for the rule that mandates following the manufacturer's specifications.

Under 1919.80(a), who must ensure that manufacturer-recommended heat treatment of loose gear is carried out correctly?

The employer is responsible for ensuring that manufacturer-recommended heat treatment is performed in accordance with the manufacturer's specifications. The standard requires the work to be carried out per the manufacturer's directions, and employers must make sure that those directions are followed on the job (1919.80(a)). Employers should also ensure personnel performing the work are trained and competent; OSHA has described employer responsibility to verify employee training and competence in other contexts (see the interpretation on qualified employee training requirements at https://www.osha.gov/laws-regs/standardinterpretations/1996-03-26-3).

Under 1919.80(a), what does “in accordance with the specifications of the manufacturer” mean for heat treatment procedures?

It means following the manufacturer's written or published directions for heat treatment exactly — including specified temperatures, times, atmosphere (if any), cooling rates, post-treatment handling, and any testing or inspections the manufacturer requires. The rule explicitly requires heat treatment to be carried out per the manufacturer's specifications (1919.80(a)). If there is any uncertainty, get the manufacturer's written procedure or clarification before proceeding.

Under 1919.80(a), what should you do if the manufacturer recommends heat treatment but provides no written specifications?

You should obtain the manufacturer's specifications in writing or documented form before performing the heat treatment and keep that documentation as evidence of compliance. The standard requires heat treatment be done according to the manufacturer's specifications, so a lack of written specs means you must request them and document your efforts to obtain them (1919.80(a)). If the manufacturer cannot provide specs, the employer must rely on qualified technical judgment and document the basis for the procedure; OSHA has emphasized employer responsibility to address hazards and provide a safe workplace in applicability guidance (see https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

Under 1919.80(a), can an employer substitute a different heat treatment procedure than the manufacturer's specification for loose gear?

No — you must not substitute a different procedure unless the manufacturer explicitly authorizes and documents an alternative. The rule requires that where heat treatment is recommended, it be carried out in accordance with the manufacturer's specifications (1919.80(a)). Any deviation should be approved in writing by the manufacturer and kept with maintenance records.

Under 1919.80(a), does the standard say who is qualified to perform the heat treatment of loose gear?

The standard does not name specific job titles; it requires the work to be done per the manufacturer's specifications and therefore implies it should be performed by personnel who are competent to follow those specifications. Employers must ensure workers are trained and competent for tasks they perform — OSHA has interpreted employer responsibility for training and competency in related standards (see https://www.osha.gov/laws-regs/standardinterpretations/1996-03-26-3) alongside the requirement to follow 1919.80(a).

Under 1919.80(a), are there any OSHA-prescribed temperatures or times for heat treating loose gear?

No — OSHA does not set temperature or time values in this rule; those specific parameters come from the manufacturer's specifications. The regulation simply requires that recommended heat treatment be performed according to the manufacturer's specifications (1919.80(a)).

Under 1919.80(a), what records should be kept to show compliance when heat treatment is performed on loose gear?

You should keep records that document the manufacturer's specifications and evidence the heat treatment followed those specs — for example, the manufacturer's procedure, date of treatment, who performed it, the equipment used, temperatures and times logged, and any post-treatment inspection results. While 1919.80(a) does not list recordkeeping steps, maintaining these records demonstrates compliance with the requirement to carry out heat treatment in accordance with the manufacturer's specifications (1919.80(a)). If the manufacturer cannot supply specifications, document your attempts to obtain them and the technical basis for any alternative procedures (see employer obligations discussed in https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

Under 1919.80(a), does the requirement apply to all ‘‘loose gear’’ items or only certain types?

It applies to any loose gear for which the manufacturer recommends heat treatment. The text states that "wherever heat treatment of any loose gear is recommended by the manufacturer, it shall be carried out in accordance with the specifications of the manufacturer," so the trigger is the manufacturer's recommendation, not the gear type (1919.80(a)).

Under 1919.80(a), can a third-party shop perform the manufacturer's heat treatment for loose gear?

Yes — a third-party can perform the heat treatment as long as the work is done exactly according to the manufacturer's specifications and the employer verifies the shop's competence. The regulation requires that the heat treatment be carried out in accordance with the manufacturer's specifications (1919.80(a)). Employers should confirm that the third party is capable and qualified to follow the specified procedure; OSHA has stressed employer responsibility to ensure worker competence and training in related interpretations (see https://www.osha.gov/laws-regs/standardinterpretations/1996-03-26-3).

Under 1919.80(a), what should be done if the original manufacturer is no longer in business and their heat treatment specifications are unavailable?

If the manufacturer cannot provide specifications, obtain equivalent specifications from authoritative sources (such as the item's designer, a qualified metallurgical engineer, or recognized industry standards), document the technical basis, and treat that documentation as the required specification. The standard requires adherence to the manufacturer's specifications when recommended; when those are unavailable you must use a defensible, documented technical basis to achieve equivalent treatment and safety (1919.80(a)). Keep records of your attempts to reach the manufacturer and the rationale for the chosen procedure; OSHA has emphasized employer responsibility to address hazards and maintain documentation in applicability guidance (see https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

Under 1919.80(a), does skipping or short-changing a required manufacturer-recommended heat treatment create an OSHA violation?

Yes — failing to perform manufacturer-recommended heat treatment as specified risks noncompliance with 1919.80(a) and can create unsafe conditions. The standard mandates that where heat treatment is recommended by the manufacturer, it must be carried out per the manufacturer's specifications (1919.80(a)). Employers who alter, omit, or fail to document required treatments could face citations for not following the regulation and for creating recognized hazards (see general applicability guidance at https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

Under 1919.80(a), if manufacturer instructions say heat treat 'as required' without details, how should an employer proceed?

You must obtain specific, actionable specifications from the manufacturer (temperature, time, cooling method, testing) before proceeding; vague instructions like "as required" are insufficient to meet the obligation to carry out heat treatment according to the manufacturer's specifications. The rule requires following the manufacturer's specifications, so clarify and document the detailed requirements with the manufacturer (1919.80(a)). If the manufacturer cannot provide specifics, document that fact and obtain a qualified engineer's written procedure as the documented basis for treatment (see employer duties discussed in https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).

Under 1919.80(a), does heat treatment form part of the certification or recertification process for shore-based material handling gear?

Yes — if the manufacturer's specifications tie heat treatment to the gear's certification or to maintaining safe service properties, then performing the required heat treatment is part of complying with certification requirements. The regulation requires that where the manufacturer recommends heat treatment of loose gear it be done according to the manufacturer's specifications, so any heat treatment the manufacturer identifies as necessary for certification must be followed (1919.80(a)). For issues around who can certify equipment and accreditation, OSHA has discussed certification procedures and competent-person concepts in a related interpretation (see https://www.osha.gov/laws-regs/standardinterpretations/1977-04-26).

Under 1919.80(a), may emergency repairs on loose gear omit manufacturer-recommended heat treatment to keep operations running?

Only if the manufacturer does not require heat treatment for that repair or if a qualified technical judgment documents that temporary measures do not compromise safety; otherwise, you must follow the manufacturer's specifications even for repairs. The rule mandates that recommended heat treatment be carried out per the manufacturer's specifications (1919.80(a)). If an employer performs a temporary deviation, they should document the safety assessment and follow up with the required heat treatment as soon as practicable, and maintain records explaining the deviation (see employer obligations in https://www.osha.gov/laws-regs/standardinterpretations/1991-02-19).