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.

January 3, 1980

                  DISTRICT SUPERVISORS

FROM:             DAVID H. RHONE
                  Regional Administrator

SUBJECT:          Interpretation of 29 CFR 1910.215(d)(3)

In response to an inquiry from Donald L. Morgan, Esquire, of Cleary, Gottlieb, Steen & Hamilton, the law firm representing American Cyanamid Co., the National Office of Compliance Programming has interpreted the subject standard on abrasive wheels in the attached letter dated December 26, 1979.

It is important that all members of your safety staff realize the significance of the attached interpretation which specifies the "contact surface" of the abrasive wheel as the mounting surface and not the grinding face as previously interpreted by some CSHOs.

Questions on this memorandum may be directed to Bill Thomas in the Technical Support Group of this office.






Donald L. Morgan, Esquire
Cleary, Gottlieb, Steen & Hamilton
1250 Connecticut Avenue, N.W.
Washington, D.C. 20036





Dear Mr. Morgan:

This will confirm a telephone conversation with a member of my staff, Mr. Joe Bode, regarding your request for an interpretation of 29 CFR 1910.215(d)(3), pertaining to a citation alleging a violation issued to the American Cyanamid Company at Willow Island, West Virginia on March 21, 1979. Please accept our apology for the delay in response.

The grinding face of an abrasive grinding wheel is not a contact surface within the meaning of the regulation.

The standard 29 CFR 1910.215 addresses abrasive wheel machinery, often referred to as grinders. The OSHA standard was adopted from portions of the American National Standards Institute consensus standard, ANSI B7.1-1970. Pages 2 and 52 of that document, copy enclosed, verify that the standard, as it was applied in this instance, was misconstrued. The surface of hazardous concern, as presented in your letter, was the grinding surface or face per ANSI definition. The contact surface, as clarified by ANSI under explanatory information, specifically concerns the mounting surfaces on the wheel.

I hope this reply is responsive to your needs. Mr. Crawford, Solicitor for OSHA, will be in contact with you. If I may of further assistance, please feel free to call or write.






Donald A. Shay, Director
Office of Compliance Programming