Are Your Lifting Practices Illegal?

Safety can get convoluted. Any of us that have been in the industry long enough have ended up in conversations that involve at least an internal "What?" if not an external one. I want to raise one of those issues that will likely cause people to say, "What?". It's very straight forward as an issue, but it's contrary to common understandings which will challenge some of what we think we know.

Using straps to lift items in a lifting device that isn't rated is illegal. And just about all of us do it. The picture at the top of this article is an example of the practice.

OSHA 1926.251 (a)(2) says, (Para) "Rigging Equipment" has to have tags, and to be rated. In (a)(4) of this section it is requires "special custom designs" to be tested to 125%. Then in 2004, an OSHA Letter of Interpretation further clarifies that "manufactured items" do not need to be tested to 125%, drawing a line between "Special custom designs" and rigging equipment generally. The point being that Rigging Equipment is inclusive of manufactured lifting devices and not limited to straps.

We understand this clearly when we talk about running straps through a pallet. Strapping up a ton of butter isn't going to be safe because the straps are on it. We understand this concept on wood boxes. Your OSB job built box is not rated at 6400 lbs because the straps are good for it. But when it comes to steel boxes and bins, Especially the stacking stillage types, we seem to want to use special pleading despite the rules never changing.

Your bins and boxes have to be rated for the load they are lifting. If you decide to use straps under them, they have to be placed as the manufacturer intended as well. We've spent so much time not executing this well as an industry, that large swaths of us are not doing this correctly. Are your people or subs doing this correctly and protecting your operations and people?

If the load is what is being rigged, then the straps are the load bearing member with the tagging. A 2x4 stick of lumber can support itself. What it can support inside of a box made of it is a different question. Consider design questions. Pine or Oak? Screws or nails? Pre drilled or probably cracked from day one? And this is where we go wrong in carrying on the thinking that we don't need rated boxes because the straps are rated. If the load is contained by something that container is now the "Rigging Equipment" and it must be tagged with a rating from the manufacturer. There are even manufacturers of boxes and platforms that seem to rely on the straps as a work around as well. That's how widespread this misunderstanding spans. And contractor after contractor buys these boxes. You should look around at what's on your site and the practices going on. Are you exposed due to this common misunderstanding?