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.

DEC 28 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 letter of April 26, in which you requested of the Occupational Safety and Health Administration (OSHA) whether the "Brett-Guard" style blade guard complies with 29 CFR 1910.213(c)(1-3), hand-fed ripsaw requirements. Additionally, during an October 16 telephone conversation with a member of my staff on the same subject you indicated that the "Brett-Guard" manufacturer informed you that the guard is not equipped with a splitter (spreader), anti-kickback fingers, and does not ride on top of the stock being cut. Please excuse the delay in our response.

We reviewed the latest "Brett-Guard" table saw guard brochure, (copy enclosed for your information) and discussed this matter with Mr. Dave McCallum, Sales Manager and Mr. Tim Hewitt, Engineer, of HTC Products, Inc., the guard's manufacturer, on October 25 and November 27. Messrs. McCallum and Hewitt informed us that the guard is equipped with the anti-kickback fingers and can be manually adjusted to afford protection. Additionally, a splitter is sent at no charge with each guard. If manually adjustable fixed barrier guards, such as the "Brett-Guard", provide protection equivalent to the protection of automatically adjusted guards thereby preventing employee exposure to the blade, as described in OSHA Instruction STD 1-12.18, October 30, 1978, OSHA will not issue a citation. A copy of the instruction is enclosed for your information. On the basis of these facts, the "Brett-Guard" when properly utilized in the workplace conforms to the requirements of 1910.213(c).

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 1(800)624-2027

If you have additional questions, please feel free to contact James C. Dillard, of my staff, at (202)523-8041.


Patricia K. Clark, Director
Directorate of Compliance Programs


GICA:SAA:JDILLARD:tf:file#saa.570 corliss comp. cc: Clark,Donnelly,Stroup,Dillard,OCIS,HRT,OTI,CHRON