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.

September 9, 1997

Mr. Kevin Finnegan
Market Manager - Heavy Duty
Flexible Steel Lacing Company
2525 Wisconsin Avenue
Downers Grove, Illinois 60515-4200

Dear Mr. Finnegan:

This is in response to your letter of August 7, requesting a confirmation that the Australian test, (AS 1334.9) Determination of Electrical Resistance of Conveyor Belting, satisfies the Occupational Safety and Health Administration (OSHA) standard 29 CFR 1910.272.

We have reviewed the information provided in your letter. Your letter indicated that the AS 1334.9 appears to be identical to the International Standard's Organization's (ISO) #284, "Conveyor Belts-Electrical Conductivity-Specification and Method of Test" at 29 CFR 1910.272, Appendix A, Section 13. As indicated in Section 13, Inside Bucket Elevators, when an employer has a written certification from the manufacturer that a belt has been tested using one of the specified test methods, and meets the 300 megohm criteria, the belt is acceptable as meeting this standard. However, please be advised that the employer has the responsibility for compliance with OSHA regulations. Because the Australian test method AS 1334.9 is not one of the test methods specified in 1910.272, OSHA would consider its use to be a de minimis violation if it is identical to ISO #284. De minimis violations are violations of standards which have no direct or immediate relationship to safety and health and shall not be included in citations.

We appreciate your interest in occupational safety and health. If you have any further questions, please contact Wil Epps of my staff at (202) 219-8041.


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