- Standard Number:
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 31, 1980
Mr. John Proctor
Organization Resources Counselors, Inc.
1625 I Street, N.W.
Washington, D.C. 20006
Dear Mr. Proctor:
This is in response to your inquiry to Bruce Hillenbrand concerning the new safety standards for servicing multi-piece rim wheels.
In response to the questions raised by your member companies, the answers are in the same order as listed in your letter.
1. The definition of "servicing" does not include work on multi-piece rim wheels equipped with tubeless radial tires. 29 CFR 1910.177 applies to the servicing of vehicle wheels which have tube-type tires mounted on multi-piece rims. Original equipment manufacturers servicing tube-type tires mounted in multi-piece rims must comply with 29 CFR 1910.177.
2. A mechanic removing wheels for inspection and repairs of brakes or framework should be trained to recognize the hazards associated with demounting and mounting multi-piece rim wheels. A garage mechanic who checks inflation pressure with a gage and then adds air, but does no other servicing, should also be trained to recognize the hazards associated with servicing multi-piece rim wheels. Drivers should also be trained to recognize hazards associated with multi-piece rim wheels.
3. Even though experienced mechanics have been following the instructions on the charts for years and comply with the requirements of 29 CFR 1910.177, they should be retrained to ensure compliance with the standards. If they are experienced, but never followed the charts, they must be trained to comply with 29 CFR 1910.177. The employer is responsible for employee training and may designate a qualified employee as a trainer.
4. At the present time, OSHA does not intend to apply parts or all of 29 CFR 1910.177 at construction sites which service large tubeless construction equipment tires. 29 CFR 1910.177(a) does not relate to tubeless tires.
5. 29 CFR 1910.177(d)(1) requires restraints for all multi-piece rims; however, it is flexible in the type of device that may be used. A "restraining device" is defined as a mechanical apparatus such as a safety cage, rack, or safety bar arrangement or other machinery or equipment specifically designed for this purpose, that will constrain all multi-piece rim wheel components up to 150 percent of maximum specification pressure for the wheel being serviced in case of an unintentional explosive separation of the assembled wheel.
6. We do not plan to develop and publish in the immediate future charts describing additional safety practices which comply with the standards for: (1) inspection of wheels on a vehicle prior to removal; (2) inflation; and (3) wheel removal and reinstallation on the vehicle.
7. It is acceptable for a mechanic to be trained only for those "servicing" activities in which that mechanic is engaged or could be exposed to during employment. However, it is recommended that all exposed employees be trained in recommended procedures of mounting, demounting and all related services for multi-piece rim wheels.
8. We do not plan at this time to publish revised charts to cover all aspects of "servicing" or to cover additional work. The activities in question include: (1) on-the-vehicle inspection and inflation; (2) removal and installation; and (3) handling and storage. This type instruction should be a part of the employer's safety training program.
If we may be of further assistance, please do not hesitate to call or write.
John K. Barto Chief,
Division of Occupational Safety Programming