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.

MAR 13 1991

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 December 10, 1990, in which you inquired if the Occupational Safety and Health Administration (OSHA) has issued any directives with regard to requirements for automatic return attachments on radial saws, in keeping with the requirements of our 29 CFR 1910.213(h)(4), radial saws standard. You also requested the Agency's official position on this matter. Please excuse the delay in our response.

OSHA has not issued any field directives nor has it rendered interpretation of the .213(h)(4) standard with respect to the use of automatic return devices or attachments on radial saws. We agree with your contention that our .213(h)(4) standard does not contain any specific language concerning the use of automatic return attachments. As you may be aware, OSHA adopted this standard from the American Standard Safety Code for Woodworking Machinery of 1954, Section 01.1-1954, R 1961, which was the latest edition at the time of OSHA's adoption. OSHA feels that the language of this requirement is interpreted as "automatic return" of the cutting head when released by the operator.

The American National Standards Institute (ANSI) standard 01.1- 1971, Safety Requirements of Woodworking Machinery, pertaining to radial saws, recommends that, as an alternative to the elevation of the front end of the saw, other devices be installed so as to cause the cutting head to return gently to the starting position when released by the operator. Additionally, ANSI 01.1-1975, on the same subject, states that a means shall be provided to prevent the cutting head from rolling or moving away from the column due to vibration or gravity, and requires the placement of a warning label instructing the user to return the carriage to the rear-most position after each cross cut.

Notwithstanding the various changes in ANSI requirements, as listed above, OSHA will continue to require that the cutting head on the radial arm saw return gently to its starting position upon release by the operator. The employer may use devices, attachments or other means to accomplish this requirement. OSHA area offices are correct in issuing citations to employers where the radial saw cutting head does not return gently to its starting position upon its release by the saw operator.

Your concern about the operator inadvertently introducing his hands into the path of the saw blade while it is returning to the column should be satisfied by appropriate saw blade guarding and employee training. In addition, your concern about the saw rebounding from the column is answered by the intent of the standard, which uses the phrase "return gently". This means that the speed of return should not allow for potential rebound.

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

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs