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 6, 1992
Mr. Douglas Payne President
Frame Master, Inc.
Post Office Box 132 South
Ryegate, Vermont 05069
Dear Mr. Payne:
This is in response to your March 4 letter requesting review and comments on your framemaster safety tool.
The Occupational Safety and Health Administration does not approve nor endorse products. The variable working conditions at jobsites and possible alterations, misuse, or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer. However, we have reviewed the product drawing enclosed with your letter and it appears that if the frame master safety tool is used correctly, the hazards associated with nailing studs, joists and rafters with a nailgun, would be reduced.
If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 523-8136.
Patricia K. Clark, Director
Directorate of Compliance Programs