On October 23, 2025, the California Department of Health Care Access and Information (HCAI) published the third revision of Policy Intent Notice (PIN) 55 — OSHPD Special Seismic Certification Preapproval Program (OSP). This revision aligns the OSP program with the 2025 California Building Code (CBC) and ASCE/SEI 7-22.
What is OSP, in one paragraph
The OSP is a voluntary HCAI program that pre-approves a manufacturer's Certificate of Compliance based on shake table testing per ICC-ES AC156. For a complete primer, see our OSHPD OSP guide.
The headline change in the October 2025 revision
- In Policy Item #19, the term "distribution line" has been replaced with "distribution system" to match ASCE/SEI 7-22 terminology.
PIN 55 now consistently references the 2025 CBC and ASCE 7-22 §13.2.3 in place of 2022 CBC / ASCE 7-16 citations.
Scope of the OSP program (2025 CBC update)
- Components requiring special seismic certification under 2025 CBC §1705.14.3, §1705A.14.3, or ASCE 7-22 §13.2.3.
- Certification based on shake table testing per ICC-ES AC156.
Active or energized equipment must be certified exclusively by approved shake table tests. Special seismic certification by analysis or experience data remain outside the OSP program.
Certification basis — what the test program must include
- Two units minimum per product line of similar configuration.
- ISO 9001 single-test exception for single products with variations limited to software, color, branding.
- Testing by an ISO/IEC 17025-accredited lab, or under the responsible charge of a California-licensed engineer per 2025 CBC §1703.4 / §1703A.4.
- Test reports reviewed and accepted by an independent California-licensed structural engineer.
- Each operating configuration simulated per AC156 §4.5.4.
- If uniaxial or bi-axial, an additional test at 45° per AC156 §6.4.1.
Multi-component systems and mounting configurations
- Structurally separate components can be certified independently.
- Connecting elements, attachments, and supports may be justified by analysis when stiffness/strength match the tested configuration.
- Each mounting configuration must be simulated.
- Rigid base-mounted components with neoprene pads ≥ ¾" must be tested with the pads.
- Stiffness of supporting structure to anchorage must be replicated or input motions modified.
Sub-component identification — how deep must the BOM go?
Per AC156 §5.2.2.1, sub-component identification one level down is generally adequate, provided unique part numbers identify configuration, manufacturer, and materials.
Pre-test meeting with HCAI — strongly recommended
- Test plan that justifies intended scope of approval.
- Scope of preapproval.
- Test standard and reporting requirements.
- Certificate of Compliance and label requirements.
OSP validity — six-year clock and what voids it
- OSP approvals are valid for 6 years.
- An OSP is void on material alterations or non-equivalent changes to strength, stiffness, size, weight, materials, support, orientation, or manufacturer.
What to update in your OSP package today
- Replace 2022 CBC and ASCE 7-16 §13.2.2 references with 2025 CBC and ASCE 7-22 §13.2.3.
- Update "distribution line" → "distribution system".
- Confirm AC156 test report includes the 45° supplemental test where applicable.
- Re-verify project-side anchorage uses the new ASCE 7-22 Fp equation — see our ASCE 7-22 Chapter 13 article.
- Refresh the Special Seismic Certification Label and Certificate of Compliance.
How PANACHE ENGINEERING helps
We help equipment manufacturers earn and maintain OSPs end-to-end. Migrating an existing OSP to the 2025 CBC, or planning a new submittal? Get in touch.
