• Standard Number:
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 https://www.osha.gov.

August 12, 1975

Mr. Arthur L. Herold
Webster, Kilcullen and Chamberlain
1747 Pennsylvania Avenue, N.W.
Washington, D.C. 20006

Dear Mr. Herold:

This is in response to your letter of April 17, 1975, requesting an interpretation of 29 CFR 1910.212(a) with the regard to the application of that paragraph to chain saws. In addition, this letter confirms the phone call of a member of my staff, Mr. Jeff Campbell, apologizing for the loss of the file, thus causing a delay in our answer.

The source standard for 29 CFR 1910.212 is established in Federal Standard 41 CFR 50-204.5. The intent of Part 50-204.5 Machine Guarding is to apply all machines. This is substantiated by the list of machines in 50-204.5(c)(4) or 1910.212(a)(3)(iv).

There is no specific Occupational Safety and Health Administration (OSHA) standard that covers the guarding of chain saws. In this situation, according to 29 CFR 1910.5, the general industry standard 29 CFR 1910.212 would apply.

When a chain blade guard would prevent an employee from using the chain saw for the particular work function assigned or the blade guard presents a hazard itself, a chain blade guard would not be required. The omission of a chain blade guard under these conditions would not be a violation of 29 CFR 1910.212(a)(3)(ii).

In certain intended uses, it would be feasible to have the saw blade guarded. For example, a one direction movement of the saw with no other obstructions to the guard, in which the operation exposes an employee to injury, would require that a saw blade be guarded. Otherwise, an apparent violation of 29 CFR 1910.212(a)(3)(ii) would exist.

This interpretation does not exempt the use of protective equipment or of applying other applicable standards.

If I may be of further assistance, please feel free to contact me.


Barry J. White
Associate Assistant
Secretary for Regional Programs