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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 8, 1994
MEMORANDUM FOR: LINDA R. ANKU
THROUGH: JOHN B. MILES, JR. DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS
FROM: ROY F. GURNHAM, DIRECTOR OFFICE OF CONSTRUCTION AND MARITIME COMPLIANCE ASSISTANCE
SUBJECT: Wedge Sockets Wire Rope Clips (Piggy-Back Clip)
This is in response to your July 11 memorandum concerning the Piggy-Back wire rope clip. OSHA's policy addressing the use of wire rope clips in conjunction with wedge sockets is outlined in the attached letter to Mr. D. Micheal Barr dated July 27. In accordance with this policy, the Piggy-Back clip can be used with wedge sockets if installed according to the manufacturer's instructions.
If we can be of any further assistance, please contact me (ext. 150) or Mr. Dale Cavanaugh at (202) 219-8136.
DATE: July 11, 1994
MEMORANDUM FOR: BERRIEN ZETTLER, ACTING DIRECTOR
ATTENTION: ROY GURNHAM, DIRECTOR OFFICE OF CONSTRUCTION INDUSTRY COMPLIANCE ASSISTANCE
FROM: LINDA R. ANKU REGIONAL ADMINISTRATOR
SUBJECT: MAY "PIGGY-BACK" DOUBLE SADDLE ROPE CLIPS BE USED FOR SECURING DEAD-ENDED WIRE ROPE IN A WEDGE SOCKET CONNECTION?
Charlie Bird, who is a safety director for the Human Construction Company, has inquired about a new type of device used for securing a dead-ended wire rope in a wedge socket connection. The device is known as a "Piggy-Back" double saddle rope clip and is described in an article in the "Rigger's Corner" section of the April/May 1993 issue of Lift Equipment. Mr. Bird has inquired as to whether such devices may be used. He has advised this office that he is going to write a letter directly to the Office of Construction Industry Compliance Assistance and request a written response regarding whether the devices may be used. He wished to obtain such guidance so as to head off potential arguments with OSHA Compliance Officers as to whether the "Piggy-Back" devices may be used.
Mr. Bird has indicated that if there is an interest it might be possible for OSHA personnel to come to one of their job-sites and observe the usage of the "Piggy-Back" device.
The preceding information is provided for your information. If you require any additional information regarding this matter, please contact John McFee of my staff at (215) 596-1201.
(For Enclosure, see printed copy)