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.

January 13, 1992

MEMORANDUM FOR:     JAMES J. CONCANNON, DIRECTOR
                   OFFICE OF VARIANCE DETERMINATION

FROM:               PATRICIA K. CLARK, DIRECTOR 
                   DIRECTORATE OF COMPLIANCE PROGRAMS

Subject:            Interpretation of Multi-piece Rim Wheel standards at 29
                   CFR 1910.177

As requested, the correspondence file on Mi-Jack Products has been reviewed. Mi-Jack Products seeks Occupational Safety and Health Administration (OSHA) concurrence that the method, as demonstrated on their video cassette tape, of mounting tires on multi-piece wheels complies with OSHA standards.

The method demonstrated by Mi-Jack Products is intended for use when servicing tires on multi-piece rim wheels which are mounted dually. Mi-Jack Products contends that their servicing procedures which include orientation of the multi-piece wheel so that the locking rings face each other provide equal or greater safety than provided by the servicing procedures and the engineering control, that is, restraining device required by 29 CFR 1910.177.

The video cassette tape provided by Mi-Jack Products demonstrates that the opposite tire contains the locking ring, tube and liner during an explosion separation of a multi-piece rim wheel. However, the method demonstrated by Mi-Jack Products does not provide equal or greater safety compared to the requirements of 29 CFR 1910.177 which include not only safe procedures but also a restraining device which, by definition, constrains all rim wheel components including wheel components as well as the tire, tube and liner. The method of mounting tires may not contain all rim wheel components. For example, pieces of an exploded tire may deviate from paths which are perpendicular to the assembled position of the rim wheel. An employee nearby, for example, standing behind the trunk may be hit by flying tire fragments.