Vietnam’s strict-safety machinery list turns a tower crane into a permanent inspection file, not a one-time certificate

▌  INDUSTRY BRIEFING  ·  SEPTEMBER 2026  ·  VIETNAM OSH

Vietnam’s strict-safety machinery list turns a tower crane into a permanent inspection file, not a one-time certificate

Vietnam’s list of machinery that must meet strict occupational safety requirements is older than most exporters assume. It sits in Circular 36/2019/TT-BLĐTBXH, issued on 30 December 2019 and in force since 1 March 2020, which replaced the original Circular 53/2016/TT-BLĐTBXH of 28 December 2016. The list names 45 categories of machinery, equipment, materials and chemicals. Behind it stands Decree 44/2016/NĐ-CP, issued on 15 May 2016 and effective from 1 July 2016, which sets out how those machines are inspected. Tower cranes, bridge cranes, gantry cranes and hoists all appear by name.

This is not a single certificate issued at handover. Decree 44 requires an inspection before first use, further inspections at fixed intervals, and unscheduled inspections after an incident, a major repair or a long period out of service. The technical procedures come from a separate set of circulars, and construction cranes follow a construction-ministry track with its own cycles and load tests. Two changes in 2025 and 2026 have moved the administrative address of occupational safety and altered what the inspection dossier must contain — while leaving the inspection cycles themselves intact.

▌  01  THE TWO DATES

▌  IN FORCE SINCE 1 JULY 2016  Decree 44/2016/NĐ-CP was issued on 15 May 2016 and took effect on 1 July 2016. It elaborates the Law on Occupational Safety and Health No. 84/2015/QH13, adopted on 25 June 2015, whose Article 33 creates the list of machinery with strict occupational safety requirements and Article 34 the inspection regime that follows from it. The decree has been amended twice: by Decree 140/2018/NĐ-CP, effective 8 October 2018, and by Decree 04/2023/NĐ-CP, effective 13 February 2023. The three texts are consolidated in document No. 2279/VBHN-BLĐTBXH of 21 June 2023.

▌  IN FORCE SINCE 1 MARCH 2020  The list itself is Circular 36/2019/TT-BLĐTBXH, issued on 30 December 2019 and effective from 1 March 2020. It superseded Circular 53/2016/TT-BLĐTBXH of 28 December 2016, which had carried the original version. A supplier still working from a 2016 reference is working from a superseded list; the current text has been in force for more than six years.

▌  02  WHAT PUTS A MACHINE ON THE LIST

▌  45 CATEGORIES, FIVE OF THEM LIFTING  The consolidated list covers 45 groups of machinery, equipment, materials and chemicals that require strict occupational safety management. Lifting equipment is not one line in it but five, and the five sit at numbers 10 to 14 of the table.

▌  NUMBERS 10 TO 14 ARE THE LIFTING FAMILY  Item 10 is cranes of all kinds (cần trục các loại). Item 11 is bridge cranes (cầu trục). Item 12 is gantry and semi-gantry cranes (cổng trục, bán cổng trục). Item 13 reaches cable cranes for transporting goods and passengers, construction vehicle-mounted cranes, tilt hoists and vertical hoists — the last of these being the construction hoist used on Vietnamese sites. Item 14 covers electric hoists of any capacity, and manual hoists rated at 1,000 kg or more. A tower crane and a construction hoist therefore live inside the same list, under different numbers.

▌  THE LIST RUNS ON THRESHOLDS  Entry to the list often turns on a number rather than a category. Manual hoists are caught only at 1,000 kg and above, while electric hoists are caught at any capacity at all. The same logic runs through the rest of the table: boilers with a working pressure above 0.7 bar, water heaters above 115 °C, forklifts from 1,000 kg of lifting capacity, lifts and escalators without qualification. When a machine’s specification crosses a threshold, it acquires a continuing obligation to be inspected — and the threshold is set by the model, not by the market.

▌  TWO ADMINISTRATIONS, ONE MACHINE  The strict-safety list and the inspection decree sit with the ministry responsible for occupational safety, while the construction procedures sit with the ministry responsible for construction. Because a tower crane is assembled on a site rather than delivered as a finished product, both apply to the same machine. Suppliers who treat the list as one ministry’s matter tend to discover the construction track only after delivery.

▌  03  WHAT INSPECTION ACTUALLY MEANS

▌  THREE FORMS OF INSPECTION  Decree 44 provides three. First inspection (kiểm định lần đầu) takes place before the machine is put into use. Periodic inspection (kiểm định định kỳ) follows at fixed intervals. Unscheduled inspection (kiểm định bất thường) is triggered by an incident, a major repair or a period out of service. The procedures that govern each are set by Circular 54/2016/TT-BLĐTBXH, issued on 28 December 2016 and effective from 1 June 2017, which supplied 30 inspection procedures and replaced the earlier Circular 07/2014 and Circular 46/2015.

▌  CONSTRUCTION CRANES FOLLOW A SECOND TRACK  A tower crane on a construction site is examined under the construction ministry’s procedures rather than the labour-ministry set. Circular 29/2016/TT-BXD, issued on 29 December 2016 and effective from 15 February 2017, published QTKĐ 01-2016/BXD for tower cranes, QTKĐ 02-2016/BXD for construction hoists and QTKĐ 03-2016/BXD for suspended platforms. The list decides that the machine must be managed strictly; this track decides how it is measured.

▌  THE CYCLES ARE LONGER THAN MANY EXPECT  Under QTKĐ 02-2016/BXD the periodic interval for a construction hoist is one year, shortened to six months once more than 12 years have passed since manufacture. Bridge and gantry cranes — the non-construction family, under QTKĐ 01-2014/BLĐTBXH — carry a three-year interval, shortened to one year beyond 12 years of use. Long intervals raise the stakes on the record rather than lowering them: a single missed cycle opens a wide gap in the machine’s history on site.

▌  LOAD TESTS ARE WRITTEN INTO THE PROCEDURE  The tower crane procedure requires a static test at 125% of the safe working load and a dynamic test at 110%. Static proof is held for ten minutes, with no slipping and no cracking or permanent deformation. The external examination covers the mast’s anchoring, which may be attached only to load-bearing structure and never to a masonry wall. Those are inspection criteria, not marketing figures.

▌  04  THE EMPLOYER’S SIDE OF THE FILE

▌  THE INSPECTION BODY MUST BE ELIGIBLE  Under Decree 44 an inspection organisation needs a certificate of eligibility, at least two inspectors on fixed-term contracts of 12 months or more, and a technical head who has worked as an inspector for at least two years. Inspector certificates run for five years. The record, stamp and result certificate must be issued within five working days. An unqualified body produces a document that does not discharge the duty.

▌  IMPORT IS A SEPARATE GATE  Lifting equipment also appears in Circular 01/2021/TT-BLĐTBXH, issued on 3 June 2021 and effective from 18 July 2021, which lists 13 categories of goods subject to state quality inspection at import, alongside eight exemptions. Clearing customs and passing in-service inspection are two different files, opened at two different moments by two different bodies.

▌  TRAINING AND MONITORING RUN ALONGSIDE  Decree 44 also elaborates the law’s provisions on safety training and on monitoring of the working environment. Three obligations therefore travel together: the machine passes inspection, the operator is trained, and the workplace is measured. An audit rarely finds only one of them missing.

▌  BREACHES ARE ADMINISTRATIVE MATTERS  Failures of occupational safety and health duty are sanctioned administratively under Decree 12/2022/NĐ-CP, the consolidated labour penalty regime of 2022. The penalty is applied to the organisation holding the duty — usually the site, not the exporter.

▌  05  WHAT IT MEANS WHEN YOU SPECIFY OR BUY

●  Does the crane arrive with a first-inspection plan, or does the buyer discover the requirement only once the machine is on site?

●  Which procedure will the inspection body work to for this model — the labour-ministry set or the construction-ministry QTKĐ?

●  What load test will the machine be asked to pass: 125% static, 110% dynamic, and for how many minutes?

●  Can the supplier’s technical dossier survive the 12-year threshold, after which the inspection interval shortens?

●  Is the monitoring and limiting system documented well enough to face an unscheduled inspection after a repair?

●  Has the importer checked the shipment against the 13 categories subject to state quality inspection at import?

▌  06  WHAT TO WATCH

●  Decree 25/2025/NĐ-CP, issued on 21 February 2025 and effective from 1 March 2025, moved occupational safety and health functions into the Ministry of Home Affairs (Bộ Nội vụ). Decree 276/2026/NĐ-CP, effective 8 July 2026, restated the arrangement. The regulator’s address changed; the technical rules did not.

●  A draft decree to replace Decree 44/2016/NĐ-CP is being prepared by the Ministry of Home Affairs. Published directions include an electronic inspection database, interconnection with the national data centre, tighter management of body and inspector certificates, and further cuts to administrative procedures. If adopted, it reshapes the inspection record more than the inspection cycle.

●  Circular 42/2026/TT-BXD, issued on 29 June 2026 and effective from 15 August 2026, amends three construction circulars. It adds QCVN 18:2021/BXD to the cited documents and removes the requirement to check the conformity certificate (giấy chứng nhận hợp quy) in the dossier for tower cranes, construction hoists and suspended platforms. It does not change the inspection intervals.

●  With cycles of one year, three years and six months running in parallel, capacity at eligible inspection bodies — not the legal text — is likely to be the practical constraint on a busy site.

●  Enforcement, rather than the list itself, is what turns a circular into a condition in a purchase order.

This briefing summarises Vietnamese national rules. It is not legal advice, and local rules still govern your site.

ABOUT

Shandong Zhinuo (ZNAQ) designs and manufactures tower crane safety monitoring systems and lifting-safety hardware for export markets, including load-moment limiting, zone-control and anti-collision functions that are increasingly software-defined. We follow Vietnam’s strict-safety equipment list and the inspection procedures that sit behind it when we prepare technical documentation for cranes and hoists.

▌  CONTACT  shandongzhinuo@outlook.com  +86 176 6371 0314 · en.znaqkj.com

SOURCES

Ministry of Home Affairs (Bộ Nội vụ), Decree 25/2025/NĐ-CP and the draft decree replacing Decree 44/2016/NĐ-CP — moha.gov.vn

Thư Viện Pháp Luật legal database, Law No. 84/2015/QH13 and Decree 44/2016/NĐ-CP (consolidated) — thuvienphapluat.vn

LuatVietnam English desk, Circular 36/2019/TT-BLĐTBXH on the strict-safety machinery list — english.luatvietnam.vn

Department of State Inspection of Construction Works Quality (Cục Giám định), tower crane load-test requirements — cucgiamdinh.gov.vn

Vietnam Chamber of Commerce and Industry legal portal, Circular 29/2016/TT-BXD — vanban.vcci.com.vn

Tạp chí Xây dựng (Construction Magazine), Circular 42/2026/TT-BXD amending three construction circulars — m.tapchixaydung.vn

Bridge and gantry crane inspection procedure QTKĐ 01-2014/BLĐTBXH — etsc.vn