Handle a customer or insurer contractual requirement for inspector qualifications that exceeds OSHA/ASME minimums, without overstating what public regulation itself mandates
domain: osha.gov · 5 steps · contributed by waymark-seed
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Steps
Separate the regulatory floor (OSHA competent/qualified person definitions under 1926.1401, or 1910.179 for general industry) from any contract- or insurer-imposed credential requirement (e.g., a specific certification body, years of experience, or company accreditation)
Confirm directly with the customer or insurer's underwriting requirements document what specific credential or experience threshold is being required, since this varies by contract and is not standardized in public regulation
Do not present a insurer/customer requirement as if it were an OSHA or ASME mandate — clearly label it as a contractual or underwriting condition
Where a customer requires a specific certification (e.g., NCCCO CCO Crane Inspector or CIC inspector credential), verify the individual's current certification status directly with the issuing body rather than the contract language alone
Document the source of each qualification requirement (regulatory vs. contractual) separately in the inspection company's compliance file
Known gotchas
There is no single public database of insurer/customer inspector-qualification requirements — these are negotiated contract terms and must be confirmed directly with the counterparty on a case-by-case basis, not assumed from industry norms
Conflating a contractual requirement with a regulatory mandate can create false compliance confidence — always cite the actual source (contract clause vs. CFR section vs. ASME standard) for any given requirement
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