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 10, 1990

Mr. Mathew A. Ros
Risk Manager
Delta International Machinery Corporation
246 Alpha Drive
Pittsburgh, Pennsylvania 15238-2985

Dear Mr. Ros:

This is in response to your letters of May 1, in which you requested copies of three specific OSHA program directives and field information memorandums regarding radial saw guards and additional information on table saw guarding systems. You also wanted to know if fixed barrier guards, such as the Brett-Guard, conform to our woodworking requirements. We appreciate your expresses support of OSHA efforts to enforce the safe and proper operation of woodworking machinery. Please excuse the delay in our response.

Enclosed are copies of the directive and memorandums you requested. OSHA Program Directive (OPD) number 100-45 of January 23, 1976, was cancelled and superseded by Field Information Memorandum (FIM) number 77-5 of February 17, 1977, which itself was combined with FIM number 76-2A and became OPD number 100-92. OPD number 100-92 was recodified as OSHA Instruction STD 1-12.18 dated October 30, 1978, without reprinting and remains current policy directive.

In regard to whether the use of fixed barrier guards, such as the Brett-Guard, conform to OSHA are requirements, the answer to this question is found in Section 4. of the enclosed October 30, 1978, OSHA Instruction STD 1-12.18. Fixed barrier guards can conform to the OSHA requirements if sections 4 a. and b. of this Instruction are adhered to. Additionally, for more specific information about the Brett-Guard, you may wish to contact the guard manufacturer at the following location:

         Mr. Dave McCallum, Sales Manager
         HTC Products, Inc.
         P.O. Box 839
         Royal Oak, Michigan  48068-0839 
         Telephone: (800)624-2027

Finally, with respect to your question concerning OSHA's preference for any particular guarding systems for table saws, please be advised that OSHA does not have a preferred guarding system. Any system in place must meet our requirements for effective guarding against injuries. We appreciate your interest in and your offer to support any efforts by OSHA to promote the safety of woodworking machinery. We will provide a copy of this letter to our OSHA Training Institute in Des Plaines, Illinois, where the Machine Guarding course is taught for both OSHA and non-OSHA personnel.

Sincerely,



Patricia K. Clark Director
Designate Directorate of Compliance Programs

Enclosures