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.

November 16, 1978

Mr. Vincent G. Biro
President and General Manager
The Biro Manufacturing Company
Marblehead, Ohio 43440

Dear Mr. Biro:

This is in response to your letter of May 5, 1978, concerning the blade guard on the Biro All Purpose Cutter, Model 100 and 200.

You indicated in your letter that to correct the ineffective guard on the cutters the company will change the rubber bumper to a nylon bumper which is more substantial. The guard will be lowered to extend down within 1/2-inch to the guide bar. You asked if this would be acceptable.

As previously discussed, to adequately guard the point of operation the guard must come down to the guide bar as shown in the Biro brochure, Poultry Processing Procedures, and as demonstrated to the OSHA staff members at F & F Foods. In addition, the guard and all components must function properly to assure maximum protection to the operator.

Thank you for your concern and continuing interest in occupational safety and health.


John K. Barto, Chief
Division of Occupational
Safety Programming