OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

August 2, 1976

Mr. Robert L. Hinman
Safety Consulting, Inc.
Post Office Box 80305
Lincoln, Nebraska 68501

Dear Mr. Hinman:

This is in response to your correspondence of June 29, 1976, regarding certain provisions of 29 CFR 1910.184, Slings.

Your first question is "... does the use of proof tested components inserted into a proof tested chain sling, require proof test the chain sling upon completion." The answer is no, as long as the additional alloy steel component to the alloy steel chain has not been physically or materially weakened in the process.

It must be remembered that when repairing and reconditioning alloy steel chain slings, mechanical coupling links or low carbon steel repair links shall not be used to repair broken lengths of chain. This prohibition is found in 29 CFR 1910.184(e)(7)(ii).

Your second question relates to the provisions of 29 CFR 1910.184(e)(l), Sling Identification. Your supposition is that when the reach of an alloy steel chain sling changes due to modification, the permanently affixed durable identification of the alloy steel chain sling would have to be changed to indicate the change in reach. This supposition is correct. It should be noted that the alloy steel chain sling shall not be used in excess of the rated capacity of the weakest component.

If I may be of any further service, please feel free to contact me.

Sincerely,



John K. Barto, Chief
Division of Occupational Safety Programming