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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.
MAR 13 1990
Mr. Robert Carson Delta International Machinery Corporation 246 Alpha Drive Pittsburgh, PA 15238-2985
Dear Mr. Carson:
This is in response to your letter of August 29, 1989, in which you requested the Occupational Safety and Health Administration's (OSHA) interpretation of the specification for lower blade guards for radial arm saws, as found at 29 CFR 1910.213(h)(1) of the standard. Please excuse the delay in our response to your request.
OSHA provided guidance to Regional Administrators on the application of 1910.213(h)(1) in its OSHA Instruction Memorandum of October 30, 1978, STD 1-12.18 (enclosed). The directive was developed to inform enforcement personnel of alternate methods of specifically meeting the intent of 1910.213(h)(1), as it pertained to guarding the sides of the lower portion of radial saw blades.
The Agency reviewed the photograph that accompanied your letter, and feels that the lower portion of the blade, as it is shown, does meet the intent of the standard as found at 1910.213(h)(1).
In regard to the modification of OSHA's 1910.213(h)(1) to reflect the latest changes of Paragraph 220.127.116.11, of ANSI O1.1 (1975), OSHA does not have this issue currently on its regulatory agenda. We will consider your letter a written request to place this issue on our future standards development/modification agenda. A copy of your letter has been provided to the Office of Safety Standards Programs for their consideration.
I appreciate your interest and effort in bringing this matter to our attention. Our Regional Offices will be reminded of the instructional memorandum addressing this matter by copy of this letter. Please feel free to contact us if you have additional concerns.
Patricia K. Clark Director Designate Directorate of Compliance Programs
JAN 31 1978
OSHA PROGRAM DIRECTIVE #100-92
TO: REGIONAL ADMINISTRATORS/OSHA
THRU: DONALD E. MACKENZIE Field Coordinator
Subject: 29 CFR 1910.213(c)(1) and (h)(1), Woodworking Machinery Guarding Requirements
The purpose of this directive is to provide guidance in the application of 29 CFR 1910.213 by specifying the application of paragraph (c)(1) to hand-fed ripsaws and paragraphs (g)(1) and (h)(1) to swing cutoff saws and radial saws.
2. Documentation Affected
This directive supersedes and cancels OSHA Program Directive #100-45 dated January 23, 1976, and OSHA Field Information Memorandums #76-2A dated January 28, 1976, and #77-5 dated February 17, 1977.
This directive was developed to inform field personnel of the alternate methods of meeting the intent of 29 CFR 1910.213(c)(1), (g)(1) and (h)(1) to eliminate employee exposure to point of operation hazards.
a. In those instances where fixed enclosures, fixed barrier guards, or manually adjusted guards are used that provide protection equivalent to the protection of automatically adjusted guards, thereby preventing employee exposure to the saw blade, no citation shall be issued.
b. Accordingly, when a fixed enclosure, fixed barrier, or manually adjusted guard is used instead of an automatic guard, it shall be considered de minimis. That is, provided the guards are used in accord with manufacturer's instructions and under sufficient supervision to insure consistent compliance with these instructions.
5. Effective Date
This directive is effective immediately and will remain in effect until canceled or superseded.
Richard P. Wilson Deputy Director, Federal Compliance and State Programs
A-1 E-1 B-2 HEW-1 C-1 NIOSH Regional Directors-1 D-4&5 NACOSH-1 Training Institute-4
August 29, 1989
Mr. Thomas Shepich Director of 0SHA Compliance Program 200 Constitution Avenue N.W. Washington, D.C. 20210
Dear Mr. Shepich:
I would like to request an interpretation on the specifications for lower blade guards for Radial Saws as documented in paragraph 1910.213 (h)(l) of the OSHA Standards.
The specific sentence I am referencing is as follows:
1910.213(h)(1) Radial Saws . . .The sides of the lower exposed portion of the blade shall be guarded to the full diameter of the blade . . .
We have had several OSHA Inspectors issue citations on Delta Radial Saws because the Inspectors claim our standard leaf guards do not completely cover the lower section of the Radial Saw blade.
I can see how an Inspector can interrupt paragraph 1910.213(h)(1) to mean that the entire lower half of a Radial Saw blade must be guarded.
We supply our Radial Saws with leaf guards which cover the tips of the teeth and gullets of a Radial Saw blade. We believe our leaf guards adequately protect the operator from accidentally contacting the hazards of a rotating saw blade, e.g., tips of the teeth and gullets. In our opinion there is no hazard in the possible accidental contact with the side of a rotating saw blade and hence we do not supply a lower blade guard on our Radial Saws that completely covers the lower half of the blade.
For your reference a photograph showing a typical leaf guard for one of our Radial Saws is shown below.
Does the Radial Saw leaf guard system described and shown above meet the intent of the OSHA Standards for lower blade guards on Radial Saws as specified in paragraph 1910.213(h)(1)?
If the Delta leaf guards comply to the intent of the OSHA requirements for lower blade guards on Radial Saws, what can be done to eliminate citations issued by Inspectors claiming the Delta Radial Saws do not comply to OSHA because the leaf guards do not cover the complete lower half of the blade?
Would it be possible to have the OSHA Standards modified such that they are in agreement with the ANSI 01.1 Standards?
Paragraph 18.104.22.168 of ANSI 01.1 (1975) states:
22.214.171.124 Hoods and Guards . . . The sides of the lower exposed portion of the saw blade shall be guarded from the tips of the blade teeth inward radially with no greater than 3/8 - inch gullet exposure . . .
As you can see from the above, the ANSI 01.1 (1975) Standard permits a leaf guard type blade guarding system for Radial Saws.
I am looking forward to your response to my questions on lower blade guards for Radial Saws. Should you need additional information on this subject, please feel free to contact me.
Robert A. Carson Project Engineer Motors and Controls