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 https://www.osha.gov.

February 27, 1997

Mr. Kevin Rohling
International Tire and Rubber Association, Inc.
P.O. Box 37203
Louisville, KY 40233-7203


Dear Mr. Rohling:


This is in further response to your November 21, 1996 letter requesting interpretation of the servicing multi-piece and single piece rim wheels standard, 29 CFR 1910.177. Please accept our apology for the delay in responding.

Specifically, you requested clarification as to what would constitute sufficient evaluation of an employee's ability to perform servicing of multi-piece or single piece rim wheels and how often additional training is needed to assure that the servicing employee's proficiency is maintained as required by paragraph 1910.177(c)(3).

The §1910.177 standard does not specify the details of the training program, but simply requires the development and maintenance of employee proficiency in given elements of servicing. See paragraph 1910.177(c)(2). A mechanic's level of proficiency must be established by demonstration of his or her familiarity with and ability to use the §1910.177 standard and the charts and rim manual referenced therein.

The training provisions of the standard are stated in performance language, allowing the employer flexibility in complying with the requirement for training. The responsibility of providing adequate training and evaluating the employee's proficiency rests with the employer.

The Occupational Safety and Health Administration (OSHA) has considered the fact that some employees may need relatively little training and practical experience to grasp the proper methods, techniques, and practices and would need little or no refresher training. Others may require additional initial training and periodic refresher training to develop and retain their knowledge of safe methods and procedures.

The training requirement in §1910.177 has been written to assure that an employee receives appropriate training to enable safe performance of tasks which are involved in servicing of both single and multi-piece rim wheels. In addition to the initial training required, this standard places a continuing obligation on the employer to evaluate the capability of each employee and assure that the employee maintains competence at servicing rim wheels. This not only insures that the initial training is effective, but also provides a means of determining the need for remedial or refresher training. OSHA will continue to determine whether an employer is in compliance with the §1910.177 requirements by workplace inspections on an application by application basis.

In your letter you also indicated that you would like to have a representative from OSHA on a Review Board (consisting of representatives from various organizations) to ensure that certification exams, developed by a Certification Committee of industry experts, are consistent with §1910.177. Please be advised that "certification exams" are not required by §1910.177. Also, OSHA does not have the funding nor personnel resources to assist you in the way which you suggested.

We appreciate your interest in Occupational Safety and Health Administration programs. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202) 219-8031, extension 110.


John B. Miles, Jr., Director
Directorate of Compliance Programs