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.

September 15, 1976

Mr. Robert L. Hinman
Resident Consultant
Nebraska Office
Post Office Box 80305
Lincoln, Nebraska 68501

Dear Mr. Hinman:

This is in response to your letter dated July 26, 1976, requesting clarification of 29 CFR 1910.212(a)(3)(ii) and 29 CFR 1910.242 as applying to hand-type office paper cutters and sharp edged hand tools.

29 CFR 1910.212(a)(3)(ii) does not apply only to power operated machinery, equipment and tools but to all equipment with point of operation hazards which may inflict injury on the operator. It is the consensus of the Division of Occupational Safety Programming that 29 CFR 1910.212(a)(3)(ii) being applicable to point of operation hazards, 29 CFR 1910.242 is applicable to the safe condition of hand-operated paper cutters.

As you know, the two most probable injuries occur from an operator dropping the blade unintentionally while the fingers are in the point of operation and the slipping of the hand holding the paper or slipping of the paper during the down stroke of the blade. As a standard deterrent to injuries from these hazards, most manufacturers have included a device with a spring load at the hinged section of the blade that will return it to the open position in the event it is released by the operator or slips from their grasp. In conjunction with the spring device, point of operation guarding is usually accomplished by either installing a single rod barrier or a shield the length of the blade attached to the cutting board. In addition, a latch is provided to lock the blade in a closed position when not in use so that the sharp edge will not be exposed.

The general requirements of 29 CFR 1910.242(a) as applies to such tools as knives, axes, shovels, hammers, chisels, etc., pertains primarily to their physical condition such as broken handles, mushroomed heads or dull edges that may cause an injury to the user. Although guards on these types of tools may not be feasible, certain other personal safety equipment such as foot, hand and eye protection may be necessary to protect the operator from injuries such as cuts and flying chips or particles.

Hopefully, this information will be helpful to you. If I may be of any further assistance, please feel free to contact me.

Sincerely,



John K. Barto, Chief
Division of Occupational Safety Programming