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OSHA 1915.113

Shackles and hooks requirements

1915 Subpart G

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.113(a)(1), what identification markings must shackles have before use in shipyard employment?

Shackles must have permanently affixed, legible identification markings from the manufacturer that show the recommended safe working load. Employers must ensure the manufacturer’s marking is both permanent and readable before putting the shackle into service. See 1915.113(a)(1).

Under 1915.113(a)(2), may I ever load a shackle above the recommended safe working load shown on the marking?

No. You must not load a shackle in excess of the recommended safe working load shown on its manufacturer’s identification marking. Exceeding the marked safe working load is prohibited. See 1915.113(a)(2).

Under 1915.113(a)(3), can an employer use a shackle that does not have affixed and legible identification markings?

No. Shackles without the required permanently affixed and legible identification markings must not be used. Employers must remove or tag out shackles that lack the required markings until they are replaced or correctly re-marked by the manufacturer. See 1915.113(a)(3) and 1915.113(a)(1).

Under 1915.113(b)(1), how should I determine the safe working load for a hook that has manufacturer's recommendations?

Follow the manufacturer’s recommendations for that specific, identifiable hook to determine its safe working load. The standard requires using the manufacturer’s published safe working loads when they exist. See 1915.113(b)(1).

Under 1915.113(b)(1), what must I do before using a hook if no manufacturer’s safe working load recommendation exists?

If no applicable manufacturer’s recommendation exists for a hook, you must test the hook to twice the intended safe working load before it is initially used. This initial test proves the hook can safely handle the intended load. See 1915.113(b)(1).

Under 1915.113(b)(1), what must be kept in the hook test certification record?

The employer must keep a certification record that includes the date of the test, the signature of the person who performed the test, and an identifier for the tested hook (for example, a serial number, tag number, or other unique ID). That record must be readily available. See 1915.113(b)(1).

Under 1915.113(b)(2), where must loads be applied on a hook and why?

Loads must be applied to the throat of the hook because loading the point overstresses, bends, or springs the hook. Always position slings or attachments so the load bears on the throat, not the tip. See 1915.113(b)(2).

Under 1915.113(b)(3), how often must hooks be inspected and what should we do if a hook is bent or sprung?

Hooks must be inspected periodically to ensure they have not been bent or sprung by overloading, and any bent or sprung hook must not be used. While the standard requires periodic inspections, use a qualified or competent person to set inspection frequency and perform evaluations based on operations and risk. See 1915.113(b)(3) and consider the role of the shipyard "competent person" described in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 for guidance on who should be making those determinations.

Under the general scope of 1915.113, to which workplaces does this shackles and hooks standard apply?

The provisions of 1915.113 apply to ship repairing, shipbuilding, and shipbreaking operations. If you work in those shipyard activities, this section’s requirements for shackles and hooks apply. See the opening text of 1915.113 and the broader Part 1915 scope.

Under 1915.113(a), what should an employer do if a manufacturer’s identification marking on a shackle is faded or partly illegible?

If a shackle’s manufacturer identification marking is not legible, the employer must not use that shackle until the marking is restored or the shackle is removed from service; the standard requires permanently affixed and legible markings. Use a replacement shackle or obtain verification from the manufacturer. See 1915.113(a)(1) and 1915.113(a)(3).

Under 1915.113(b), may a hook that has been bent be straightened and returned to service?

No. A hook that has been bent or sprung by overloading must not be used. The standard does not authorize returning bent or sprung hooks to service; replace the hook or follow the manufacturer’s written guidance for repairs if any exist. See 1915.113(b)(3) and consult the hook manufacturer’s recommendations as required by 1915.113(b)(1).

Under 1915.113(b)(1), what is considered an acceptable "identifier for the hook" in the required test certification record?

An acceptable identifier for a tested hook is any unique means to trace the record to a specific hook, such as the manufacturer’s serial number, a metal tag number, a stamped marking on the hook, or an employer-applied durable ID. The identifier must allow someone to match the test record to the actual hook. See 1915.113(b)(1).

Under 1915.113, who is responsible for ensuring shackles and hooks meet these requirements on a shipyard site?

The employer is responsible for ensuring shackles and hooks meet the requirements of 1915.113, and the employer may assign a qualified or competent person to perform inspections, testing oversight, and recordkeeping. OSHA’s shipyard competent person guidance explains that a competent person must be capable of recognizing hazards and specifying protections in shipyard operations. See 1915.113 and OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 regarding the role and responsibilities of a competent person in shipyards.

Under 1915.113(b)(1) and (b)(3), are periodic load tests required for hooks after the initial test if no manufacturer recommendation exists?

The standard requires an initial test to twice the intended safe working load for hooks lacking manufacturer recommendations and requires periodic inspections (to detect bending or springing). It does not mandate routine periodic load testing after the initial test unless the manufacturer’s recommendations or site procedures require it; however, if inspections or conditions indicate damage or doubt about integrity, additional testing is appropriate. See 1915.113(b)(1) and 1915.113(b)(3).

Under 1915.113(a)(1), does the standard require manufacturer markings to be written in English?

The standard requires identification markings to be permanently affixed and legible and to indicate the recommended safe working load, but it does not specify a required language. Practically, markings must be understandable to those who use the equipment; if workers cannot read the marking, the employer should provide translation, re-marking by the manufacturer, or remove the part from service. See 1915.113(a)(1).

Under 1915.113(b)(1), who may perform the twice-the-load test for hooks and sign the certification record?

The person who performs and signs the test must be identified on the certification record; while the standard does not prescribe a specific job title, the test should be done by a qualified person capable of performing the test safely and documenting results. Assigning a competent or qualified technician is good practice. See 1915.113(b)(1) and OSHA’s guidance on competent persons at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 for help identifying who is qualified to make these determinations.

Under 1915.113, can employers use load charts, calculations, or an engineering assessment instead of a manufacturer’s marking to set a shackle’s safe working load?

For shackles, the standard requires the manufacturer’s permanently affixed and legible marking indicating the recommended safe working load; you cannot rely solely on your own calculations in place of that marking. For hooks, the standard requires following the manufacturer’s recommendations when available, and if no recommendation exists you must test the hook to twice the intended safe working load. Engineering assessments can support a safe working load but do not replace the requirement for manufacturer markings on shackles or the required hook testing where no manufacturer guidance exists. See 1915.113(a)(1) and 1915.113(b)(1).

Under 1915.113(b)(3), what should we do if a hook shows wear or deformation that isn’t clearly a bend or spring?

If a hook shows wear or any deformation that raises concern, remove it from service until a competent or qualified person inspects and determines whether it is safe; any hook visibly bent or sprung must not be used. Employers should follow manufacturer guidance or have the hook evaluated and, if necessary, load-tested or replaced. See 1915.113(b)(3) and consult OSHA’s shipyard competent person guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 on who should make such determinations.