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.

October 3, 1980

Mr. Blaine L. Cosbey
Vice President/General Manager
Modern Foundry & Manufacturing Co.
South Sixth Street
Mascoutah, Illinois 62258

Dear Mr. Cosbey:

This is in response to your letter addressed to a member of my staff concerning OSHA's protective clothing requirements for molders pouring iron.

29 CFR 1910.132(a) requires protective equipment, including personal protective equipment for eyes, face, head and extremities, protective clothing, respiratory devices, and protective shields and barriers to be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary, by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

The issue of employees wearing shirts or being uncovered above the waist when transporting, pouring, skimming, casting, etc., is one that has been reviewed by this office. Employers not requiring employees pouring iron to wear protective clothing may be cited for a serious violation of 29 CFR 1910.132(a), because of the potential exposure to severe burns.

We can not consider the granting of a variance in this type of employee exposure, because employees issued a variance must provide the equivalent protection for employees as required in 29 CFR 1910.132(a). Molders pouring their iron without protective clothing would be unprotected above the waist.

If we may be of further assistance, please call or write.


Bruce Hillenbrand
Acting Director,
Federal Compliance And State Programs