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.

April 2, 1991

Mr. Robert F. Harold
President
R. F. Harold & Associates, Inc.
1470 Enterprise Parkway
Twinsburg, Ohio 44087

Dear Mr. Harold:

This is in response to your letter of March 6, in which you requested an interpretation as to whether bolt-together, divided wheels are included in the definition of the Servicing Multi- Piece and Single Piece Rim Wheels Standard (29 CFR 1910.177).

29 CFR 1910.177 defines a multi-piece wheel as one consisting of two or more parts, one of which is a side or locking ring designed to hold the tire on the wheel by interlocking components when the tire is inflated. A review of the schematic revealed that the type of wheel depicted was of an aircraft type wheel that did not have a side or locking ring. This standard only covers multi-piece rim wheels containing a lock ring, or side ring and base. Therefore, bolt-together, divided wheels are not covered by this standard. This is explained in the enclosed page 6708 of Vol. 45, No. 20 of the Federal Register.

Although this particular type of wheel is not covered by 29 CFR 1910.177, employers are still obligated to provide protections for their employees. Failure to do so could result in a proposed citation and penalty under the general duty clause (Section 5 (a)(1)) of the Occupational Safety and Health Act.

Your interest in workplace safety and health is appreciated.

Enclosure

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs