- Standard Number:
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 4, 2000
Mr. David Miguel
Shoring and Supply Co., Inc.
7700 Wedd Street
Overland Park, KS 66204
Dear Mr. Miguel:
This is in response to your October 17, 1999, letter to the Occupational Safety and Health Administration (OSHA) in which you ask a question relating to the requirements of using alloy steel chains for material handling. We apologize for the delay in issuing a response.
Question: Is it acceptable to use a sling of less than Grade 80 alloy chain if the load is lifted off the ground but never over the heads of employees?
Answer: Section 1926.251(a)(2) states that "rigging equipment shall not be loaded in excess of its recommended safe working load, as prescribed in Tables H-1 through H-20..." (also, §1926.251(b)(4) states that the rated capacity for alloy steel chain slings shall conform to the values in Table H-1). Table H-1 prescribes rated capacities (working load limits) for alloy steel chain only. Therefore, the standard mandates that only alloy steel chain be used, and that such chain meet the Table H-1 rated capacities.
Section 1926.251 does not specify a particular grade of "alloy steel chain" for rigging material lifts. Nor does it list capacities for various grades of alloy steel chain. Rather, it lists capacity requirements for various sizes of alloy steel chain when used at various angles and configurations. So, whatever grade of alloy steel chain that is used, it must meet the capacity requirements listed in Table H-1. Therefore, steel alloy chain of less than Grade 80 can only be used if it meets the capacity requirements listed in 29 CFR 1926.251.
Many employers choose to use Grade 80 because it will meet or exceed the Table H-1 requirements for the various sizes, angles and configurations. A lesser grade is permitted to be used only if it meets the Table H-1 requirements. You raise the issue of whether these requirements apply if the load is not lifted over the employees' heads. The standard, by its terms, does not condition the application of the requirements to overhead loads. In fact, §1926.550(a)(19) (general requirements for cranes and derricks) states that "all employees shall be kept clear of loads about to be lifted and of suspended loads." The rigging requirements apply equally when employees are kept clear in accordance with this requirement. Even employees who are not directly under a load can be exposed to the hazard of failed rigging. When a rigging chain brakes, the material will not always fall straight down; it can shift and/or swing and then fall over a fairly broad area, depending on the height, weight, type of load, etc. There are also situations where the falling load can collapse a working surface.
If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction