Standard Interpretations - Table of Contents Standard Interpretations - Table of Contents
• Standard Number: 1910.184(e)(2)(i); 1910.184(e)(2)(ii); 1910.184(f)(6)


This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.


October 19, 2009

Mr. Rich Overton
P.O. 542
Hampton Bays, NY 11946

Dear Mr. Overton:

Thank you for your October 28, 2008, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). We apologize for the delay in our response. Your letter has been referred to DEP's Office of General Industry Enforcement (GTE) for an answer regarding OSHA's Slings standard, 29 CFR 1910.184. Your questions have been restated below for clarity.

Question 1: Has OSHA changed its standard on slings or issued an interpretation that allows chain slings and hooks to be attached with clevis pins and cotter pins?

Response 1: OSHA has not changed its standard on slings, nor has OSHA issued a letter of interpretation with respect to the use of clevis pins and cotter pins to attach slings and hooks. 29 CFR 1910.184(e)(2)(i), which addresses alloy steel chain slings, states that "[h}ooks / rings, oblong links or other attachments shall have a rated capacity at least equal to that of the alloy steel chain with which they are used or the sling shall not be used in excess of the rated capacity of the weakest component." 29 CFR 1910.184(e)(2)(ii) states, [m]akeshift links or fasteners formed from bolts or rods, or other such attachments, shall not be used." Unless the clevis pins or cotter pins are rated pursuant to the requirements of 29 CFR 1910.184(e)(2)(i), they would be considered "makeshift," pursuant to 29 CFR 1910.184(e)(2)(ii), and cannot be used.

Question 2: What is OSHA's position pertaining to latches on sling hooks?

Response 2: OSHA's standard 29 CFR 1910.184(c)(6) requires that slings shall be securely attached to the loads; however, this section does not clearly require that the hook be equipped with a safety latch. OSHA has other standards that are explicit in regards to latch type hooks. A member of my staff replied to your initial inquiry on July 16, 2009 and requested additional information regarding the industry which you were concerned. Based upon your reply, I am enclosing an OSHA interpretation letter that addresses your concerns regarding latches on sling hooks.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain the 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. In addition, 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. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs


Standard Interpretations - Table of Contents Standard Interpretations - Table of Contents