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.

July 12, 1990

Mr. Richard P. Ramsey
81 Bartlett Drive
Madison, Connecticut 06443

Dear Mr. Ramsey:

Thank you for your letter of June 13, in which you made a request for clarification of 29 CFR 1910.184(d) as follows:

a. "This letter concerns Wire Rope Slings and their inspection. The applicable standard is 29 CFR 1910.184."

b. "The product involved is Braided Slings." "The loop of hand-braided sling is formed of parallel parts of rope with nothing to hold them together. When the braiding is completed, the loop is tightly "served" (wrapped), with steel wire or strand to bind the six of eight parallel ropes together and to protect them." "We recently had called to our attention a compliance action requiring removal of the protective seizing." "This is not a reasonable position so far as this unique product is concerned. Removal of the seizing renders the sling unsafe since there is nothing to maintain the integrity of the loop."

c. "Both the wire seizing and the new plastic seizings are more vulnerable than the wires underneath. If the seizing is in good condition there should be no reason to remove it."

The following is our specific response to your request:

a. The daily inspection of the slings before use includes, as appropriate, more than just a visual glance. However, in the promulgation of this standard OSHA did not intend for a sling to lose its utility through the inspection process. The standard requires a thorough examination of the sling, but does not require the protective seizing of nylon wrapping to be removed.

b. We are advising our field offices of your concerns and providing them a copy of this response.

If we may be of further assistance, please contact us. Thank you for your interest in safety and health.

Sincerely,



Gerard F. Scannell
Assistant Secretary