June 24, 1981
MEMORANDUM FOR: VERNON A. STRAHM
THRU: JOHN. B. MILES, JR.
FROM: BRUCE HILLENBRAND
FEDERAL COMPLIANCE AND STATE PROGRAMS
SUBJECT: Guarding of Alligators Shears
As you are aware, alligator shears are used in a great variety of situations
and may not be generally compatible with any one guarding method or concept.
In instances where the shear is exclusively used for routine cuts on
standardized stock, safeguarding of the point of operation is definable. In
other instances, the operator is safeguarded from exposure to the point of
operation by the physical size and configuration of the material being cut.
However, a worrisome hazard regarding the use of this machine stems from the
exposure of the employee to impact from the free end of the material at the
time of cutting. Consideration needs to be given to the necessity for
material hold down devices.
The National Safety Council data sheet 213 (copy attached) provides
excellent guidance for evaluation and safeguarding of alligator shears.
The unique application of the alligator shear to each set of circumstances
requires an individual evaluation of the associated hazards by a safety
professional. There is no single safeguarding method, of which we are aware,
which offers a practical solution for all uses of an alligator shear. Good
safety engineering judgement must be applied when considering each
application of the machine. Hazardous applications involving alligator
shears are violations of 29 CFR 1910.212(a)(1) or (a)(3)(ii).