An OSHA Letter of Interpretation, published in October 2009, addresses whether OSHA will enforce the new gate strength requirements for carabiners and snaphooks published in the ANSI Z359.1-2007 standards.
Although there is an OSHA standard (29 CFR 1926 Subpart M, section 1926.502(d)) that addresses the hazard of a snaphook or dee-ring failing due to tensile load, this hazard is separate and distinct from the one addressed in section 22.214.171.124.2 of ANSI Z359.1, which addresses failure due to compressive load. This is more commonly referred to as gate loading in both the front and side manner. Terms often associated with this failure are forced roll-out, burst out and blow out. Remember, OSHA requires locking snaphooks but did not specify the gate strength. Only ANSI specified gate strength.
The OSHA Letter of Interpretation says that the industry has recognized a hazard of snaphooks or dee-rings failing from inadequate compressive load strength and that there is a feasible means to abate this hazard – use of equipment designed to withstand at least 3,600 pounds of compressive load. Therefore, use of such equipment is required under the OSHA General Duty clause. While equipment that meets the ANSI Z359-1992 can still be used safely, this letter definitely spells out a higher level of duty.
To read the entire OSHA Letter of Interpretation, please click on the following link: OSHA LOI 2009 10 13