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.

December 10, 1991

The Honorable Charles E. Grassley
United States Senate
Washington, D.C. 20510

Dear Senator Grassley:

Thank you for your letter of September 19, regarding concerns raised by your constituent, Mr. Gregory Ramsell, about Occupational Safety and Health Administration (OSHA) regulations. Mr. Ramsell works as a dishwasher and asserts the need for regulations covering sharp knives and utensils because he is injured often.

There are several existing standards that address the kind of situation described by Mr. Ramsell. The Occupational Safety and Health Act (OSH Act), in Section 5(a)(1), provides that each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. The general requirements of OSHA's "Personal Protective Equipment" regulation states, in part, that protective equipment for extremities shall be provided, used and maintained wherever hazards are encountered that are capable of causing injury or impairment. These rules are not specifically directed at sharp knives and utensils, but they can be applied to this situation. The use of rubber-lined, metal-mesh gloves or other protective gloves similar to those used in the meat packing industry could be explored by Mr. Ramsell's employer.

As you may know, the State of Iowa administers its own federally-approved and monitored workplace safety and health program under the authority of Section 18 of the OSH Act. While the regulations adopted by such State programs must be at least as effective as those of Federal OSHA, they may differ in some respects. For further information, you or Mr. Ramsell may wish to contact:

Mr. Allen J. Meier, Commissioner
Iowa Division of Labor Services
1000 E. Grand Avenue
Des Moines, Iowa 50319
Telephone: (515) 281-3447

If we can be any further assistance, please do not hesitate to contact us.


Gerard F. Scannell
Assistant Secretary