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October 7, 1987
MEMORANDUM FOR: JOHN PLUMMER, DIRECTOR
FEDERAL AGENCY PROGRAMS
FROM: DONALD A. SHAY, DIRECTOR
GENERAL INDUSTRY COMPLIANCE ASSISTANCE
SUBJECT: Safeguarding of Metal Cutting Do-All Saw at
the Norfolk Naval Shipyard
The information provided by the Norfolk Naval Shipyard has been reviewed.
The ANSI B11.10-1983, Safety Requirements for the Construction, Care and Use
of Metal Sawing Machines, is the appropriate consensus standard. Section
2.24.2 and E2.24.2 of the ANSI B11.10-1983, including illustration 2, defines
the point of operation as including the portion of the saw which was cited.
Therefore, 29 CFR 1910.212(a)(3)(ii) is applicable to the circumstance and 29
CFR 1910.212(a)(1) was inappropriately cited. (Ref. enclosure.)
Under 29 CFR 1910.212(a)(3)(ii), the point of operation shall be safeguarded
in conformance with any appropriate standard---. Since no applicable OSHA
standard exists, the appropriate industry consensus standard is ANSI
B11.10-1983.
The saw in contention is deemed to be in compliance with 29 CFR
1910.212(a)(3)(ii) by virtue of the fact that it is in compliance with the
intent of Section 5.4.3 of the ANSI B11.10, as verified by the ANSI B11.10
committee. The letter of March 4, 1987, from Mr. William Atkinson, Jr.,
Secretary to the B11 Standard Committee clarified the acceptability and the
limitations of the current use of the DO-All metal cutting saw at the Naval
Shipyard. The photo's provided by the Navy verify that the configuration of
the saw and the pictorial data provided to Mr. Atkinson are identical.
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