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 https://www.osha.gov.

May 3, 1977

Mr. Allen L. Wilson
Assistant Corporate
Safety Manager
General Office, AB4B
Caterpillar Tractor Company
Peoria, Illinois 61629

Dear Mr. Wilson:

This is in response to your letter of March 21, 1977, addressed to Mr. Donald Shay, regarding clarification of 29 CFR 1910.184(e)(4) as it applies to proof testing, as a unit, certain types of alloy steel chain lifting devices.

29 CFR 1910.184(e) Alloy Steel Chain Slings, does not address special alloy steel chain lifting devices, the strength of which depends upon components other than commonly used stock items such as hooks, rings, oblong links, pear shaped links, welded or mechanical coupling links, or other attachments.

When the employer in general industry designs and manufactures an alloy steel chain lifting device composed of special components such as spreader bars, accepted engineering practices or other OSHA standards may be used as guides for proof testing the device as a unit.

29 CFR 1926.251(a)(4) in Construction Regulations requires certain lifting devices to be marked to indicate the safe working load and be proof tested prior to use to 125 percent of its rated load.

29 CFR 1918.61(b) in Longshoring Regulations requires proof tests varying from 125 percent to 110 percent in excess of its safe working load for all special stevedoring gear described in the standard.

It would be inappropriate to answer your two questions as they are written due to the connotations involved.

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


John K. Barto,
Division of Occupational Safety Programming