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.

May 15, 2015

Joshua Rubero
Associate Engineer
D.H. Charles Engineering, Inc.
4706 Hoen Avenue
Santa Rosa, CA 95405

Dear Mr. Rubero:

Thank you for your June 11, 2014 letter to the Occupational Safety and Health Administration (OSHA) Directorate of Construction. You have a specific question concerning the appropriate calculation for a factor of safety six of suspension wire ropes with wire rope clip terminations. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence. We have paraphrased your question below.

Question:

Whether the allowable load rating of the suspension wire rope be based with or without the consideration of the efficiency of the end connection?

Response:

The allowable load rating must include the consideration of the efficiency of the end connection. If the end connection efficiency is less than 100%, then the load rating of the wire rope must also be accordingly reduced.

29 CFR 1926.451(a)(3) provides:

"Each suspension rope, including connecting hardware, used on non-adjustable suspension scaffolds shall be capable of supporting, without failure, at least 6 times the maximum intended load applied or transmitted to that rope." (Emphasis ours).

When wire rope clips are used at wire rope end terminations on non-adjustable suspension scaffolds, loads are transmitted through the connecting hardware of the wire rope clips at its end terminations. The wire rope clips are an integral part of the wire rope supporting the load because weight of the load is transmitted through it. Since wire rope clips reduce efficiency of the wire rope below 100%, the load rating of the must also be accordingly reduced.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,

James G. Maddux, Director
Directorate of Construction