OSHA Requirement for Proof Testing of Lifting Lugs

[AWDMIKE]

I have a question/comment regarding the applicability of OSHA proof testing requirements to welded head lugs and tailing lugs.

Here in the USA, OSHA 1926.251 applies to vessel lifting lugs and requires a proof test to 125% of the rated load of the lug.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10686

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27299

(interpretation)

It is my understanding that without a doubt, a removable flange lug which may be used for multiple vessels requires a proof test per OSHA requirements.

However, I have seen hundreds of vessels with welded top head lugs and in all cases have not had proof testing of the lugs. I believe the argument is that they are classified as being mass produced (as this would preclude them from proof testing). Furthermore, even though they have slight differences for each application, they are still the same type of lug with a similar geometry.

I was interested to know the opinion of anyone else with experience on the matter.

Thank you.

 

[DG72]

Bump...I am anxiously awaiting someone smarter than me to respond.

 

[doct9960]

AWDMIKE,

Lifting or tailing lugs welded directly to the vessel are "integral" parts of the vessel. They are not part of rigging equipment and its accessories. Hence, lugs welded to the vessel are not in the scope of OSHA 1926.251.

 

[JStephen]

I agree with the above. You have one set of rules for lifting devices, but that does not imply that the load itself has to be tested in some way.

 

[MJCronin]

To all,

In my opinion, this whole arguement pivots on the OSHA definition of "rigging equipment" and "accessories"

As I read the standards and the interpretations "rigging equipment" and "accessories" must be removable from the body of the load. (although this is not clearly stated)

Welded, permanent lifting and tailing lugs, trunions, etc would not fall under these definiitions.

A BOLTED lifting flange on a manway or nozzle would fall under these definitions....even though it was meant for a single lift.

I do not believe that it is practical to test a welded lifting lug at 125% of its design load without doing some kind of local damage to its intended load.

I suggest the liberal use of descriptive adjectives.....such as bolted and integral or welded.

-My opinion only

-MJC