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 17, 1992

Ms. Jacqueline Nowell, CIH
Assistant Director
Office of Occupational Safety and Health
Collective Bargaining Department
United Food & Commercial Workers
International Union, AFL-CIO & CLC
1775 K Street, N.W.
Washington, D.C. 20006

Dear Ms. Nowell:

Thank you for your letter of February 25 requesting an interpretation of OSHA Program Directive #100-49. Specifically, you asked whether the provisions of the directive apply to current retail meatcutting operations in the retail food industry. Please accept our apology for the delay in this response.

The directive's content, which addresses hazards to and personal protective equipment (PPE) for the hands and the torsos of retail meatcutters, is unchanged. PPE must be provided, used and properly maintained for these workers. Where the work, such as providing service to customers, requires frequent removal of wire mesh gloves, the use of protective gloves is not, however, required. The standard does not address who is to pay for the PPE.

The reference to wire mesh in the directive is to provide an illustration of cut resistance; equivalent materials may be used. A glove made of a material similar to DuPont's "Kevlar" is a possible substitute. The prohibitions against wire meshed glove usage while operating power equipment referenced in the directive are still applicable.

OSHA's directive system was renumbered on October 30, 1978; the subject directive is now "OSHA Instruction STD 1-6.1". If you have questions on these matters, please contact Mr. Donald Kallstrom of General Industry Compliance Assistance on (202) 523-8031.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs