OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

July 14, 1975

MEMORANDUM FOR:   Don Shay

Subject:          Garb-el Food Waste Disposal Unit

A complete review of all the information concerning the Garb-el Food Waste Disposal Unit has been completed. Even with the utilization of the thermoplastic trim board, which we believe adequately guards one of the pinch points, a violation of 29 CFR 1910.212(a)(i) or 29 CFR 1910.212(3)(iii) still exists.

The manufacturer has proposed the use of a Hytrel 92A blade extension made of a modulus elasticity material. A review of this blade by the Buffalo Area Director was accomplished on approximately July 2, 1976. Mr. Schwender's recommendation is not to accept the Hytrel blade. This office recommends two other possible solutions:

(1) The installation of a mesh cage guard completely enclosing the hopper opening and an interlock device between the cage and screw conveyor to stop the screw when in operation (similar to the one presently used by A&P).

(2) The installation of a small guard directly over the pinch point which could extend out from the side of the hopper and prevent the fingers from being exposed to the pinch point.

Either of the suggested methods would meet the intent of the OSHA guarding requirements. Both will provide employee protection.



John K. Barto, Chief
Division of Occupational Safety Programming