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Equivalent entities for chain and sling repairs

Summary An attorney asked who could act as an equivalent entity for chain and sling repairs. OSHA said the organization needed equipment, knowledge, and skill equal to the manufacturer’s for the repair and testing. Manufacturer-designated service representatives could qualify when working under the maker’s instructions.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1979-12-11-0
Date issued
December 11, 1979
Status
Active
Status last verified October 10, 2026

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December 11, 1979

Mr. Lee Dale
Dawson, Nagel, Sherman & Howard
[Recipient address omitted]
Dear Mr. Dale:

This is in response to your request for an interpretation of the phrase "equivalent entity" with reference to our standards regarding chains and slings.

An "equivalent entity" is defined by the general industry standard 29 CFR 1910.184(b), which states: A person or organization (including an employer) which, by possession of equipment, technical knowledge and skills, can perform with equal competence the same repairs and tests as the person or organization with which it is equated.

In general, manufacturers of chains and their designated service representatives are considered to be "equivalent entities" with regard to making repairs of alloy steel chains. Manufacturers of alloy steel chains often designate "equivalent entities" under a licensing arrangement between the parties. The various methods by which alloy steel chains are repaired and/or refurbished are very complex and require extensive equipment as well as highly skilled personnel. Any company may approach the manufacturer to establish an agreement, and where such an agreement is in force and the work accomplished in accord with the manufacturer's instructions, OSHA would consider this to be in compliance with the standard.

Slings made with chains are required to be in compliance with the manufacturer's specifications, the standards, or may be specifically constructed to specifications prepared by a licensed professional engineer familiar with the technology and authorized to develop such specifications.

If we may be of further assistance, please feel free to call or write.

Sincerely,
Grover C. Wrenn Director,
Federal Compliance and State Programs

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