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.

February 5, 1986

Ron Hutson
Territory Manager
Ammco Tool
Box 125
Canute, Oklahoma 73626

Dear Mr. Hutson:

This is in response to your December 16, 1985, letter to Mr. Saulter which was forwarded to our office for response.

The scope of 29 CFR 1910.177 defines coverage of the standard explicitly to the servicing of multi-piece and single piece rim wheels used on large vehicles such as trucks, tractors, trailers, buses, and off-road machines, It does not apply to the servicing of rim wheels used on automobiles, or on pickup trucks and vans utilizing automobile tires or truck tires designated "LT". Trucks equipped with tires designated as "LT" are outside the scope of the standard at 29 CFR 1910.177.

In the interest of safety, as a minimum, it is recommended that the servicing of all tires conform to the recommendations of the wheel and tire manufacturers as described by their various bulletins to customers. According to the Rubber Manufacturers Association, 9.50 R 16.5 LT Light Truck Wide Base Tires load range E, may be inflated to a cold inflation pressure not exceeding 80 psig when mounted on 15 degree drop center rims designated for the use of such tires. Rims or wheels should bear identification by the manufacturer indicating the conditions of use in normal highway service and should include:

       Max Load_______LBS (D) or (R) ______Max. PSI Cold

(D) means:   Diagonal (Bias) Ply or Bias Ply only.  (except bias wire carcass)

(R) means:   Radial Ply and Diagonal (Bias) Ply or Bias Belted (except bias wire carcass)

Rims or wheels not identified, or for special conditions of use, require consultation with the rim or wheel manufacturer to determine the load, inflation and tire construction limits.

Sincerely,



John B. Miles, Jr., Director
Directorate of Field Operations




December 16, 1985

Gilbert J. Saulter, Regional Administrator
US Department of Labor - OSHA
555 Griffin Square Building Rm. 602
Dallas, Texas 75202

Dear Mr. Saulter:

In regards to OSHA laws 1910.177. (A) Scope. (1) servicing of multi-piece and single piece rim wheels. The Standard does not explain in detail which is a truck tire.

This past week in Austin, Texas a man was killed servicing a 9.50 X 16.5 tire, which is used on three-quarters and one ton trucks. There are tires which are stamped LT and some aren't and have air pressure of 75 to 80 pounds.

Would you please reply as to which is covered by the standard on one-half, three-quarters and one ton trucks?

Thanking you in advance for your help.

Respectfully,



Ron Hutson
Territory Manager
Ammco Tool
Box 125
Canute, Okla. 73626