- Standard Number:
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.
October 19, 1994
Mr. R.A. Carson
Delta International Machinery Corporation
246 Alpha Drive
Pittsburgh, Pennsylvania 15238-2985
Dear Mr. Carson:
This is in response to your July 14 letter in which you addressed several questions regarding the 29 CFR 1910.213 Standard (Woodworking Machinery Requirements). Specifically, you requested information relating to radial saws under paragraph (h)(4) of the Standard. Please excuse the delay in our response.
The general question that you asked was whether OSHA is planning to update the 1910.213 Regulation such that it would agree with the latest National Consensus Standard, ANSI 01.1-1992. Please be advised that Paragraph 184.108.40.206.6 of the subject ANSI Standard (Anti-roll out) requires that a means is provided to prevent the saw carriage from moving forward on the arm as a result of gravity or vibration. Please note that this requirement incorporates OSHA's requirement for returning the cutterhead to its original position. That is, since the OSHA standard is a precursor to the ANSI standard, compliance with the ANSI standard could not be achieved unless compliance with the OSHA standard has already been achieved. Therefore, in response to this question, OSHA is satisfied that the existing standard provides the intended protection for operators of radial saws, and does not plan to update the standard at this time.
With regard to your specific questions, please find in the following the requested response.
Question 1: Must we supply our Radial Saws such that the cutterhead will return gently to the starting position when released by the operator? That is, does OSHA still require a Radial Saw to comply to the specific wording of 1910.213(h)(4)?
Response. OSHA requires that a radial saw complies to the specific wording of 1910.213(h)(4). A detailed letter pertaining to this matter was sent to your company in 1991. For your convenience, I am attaching a copy of that letter. Since OSHA's requirement remains the same, please refer to the attached letter for more information regarding 1910.213(h)(4). With regard to the Model 10 Deluxe Radial Saw cutterhead, your letter did not include the information upon which you relied in making the determination that the cutterhead will not fall due to gravity. Therefore, in the absence of this critical information, compliance with OSHA requirements (1910.213(h)(4)) remain the same.
Question 2. Would a Radial Saw in which the cutterhead does not gently return to the starting position when released by the operator, but complies to the ANSI 01.1-1992 requirement of the cutterhead not moving forward on the arm due to gravity or vibration be considered to be in compliance with OSHA?
Response. The ANSI Standard requires the employer to provide a means to prevent the saw carriage of a manually operated saw from moving forward on the arm as a result of gravity or vibration. OSHA Standard, 1910.213(h)(4) states, "Installation shall be in such a manner that the front end of the unit will be slightly higher than the rear, so as to cause the cutting head to return gently to the starting position when released by the operator." The OSHA standard is explicit in specifying the means for providing the needed protection, in order to eliminate human error (the operator's) and mishaps. Therefore, to be in compliance with OSHA and avoid any citations, the radial saw must comply with 1910.213.
Thank you for your interest in occupational safety and health. If we could be of further assistance, please contact us.
John B. Miles, Jr., Director
Directorate of Compliance Programs