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.

February 10, 1999

Mr. Robert Pritchard
The Western Group
1637 N. Warson RD.
St. Louis, MO. 63132

Re: 1926.304; ANSI 01.1-1967

Dear Mr. Pritchard:

Your letter, dated August 28, 1998, to the Occupational Safety and Health Administration (OSHA) contained three questions concerning our reference in 29 CFR 1926.304 to the ANSI Standard 01.1-1967, Safety Code for Woodworking Machinery.

Does §1926.304 require a table saw to be equipped with a magnetic switch, or similar switch that disengages after power loss?

In addition to specific requirements set out elsewhere in §1926.304, .304(f) requires that all woodworking tools and machinery meet other applicable requirements of ANSI 01.1-1961. Section 3.1.3(c) of the ANSI standard requires:

On applications where injury to the operator might result if motors were to restart after power failures, provisions shall be made to prevent machines from automatically restarting upon restoration of power.

This is a "performance" standard -- where injury can occur in this type of situation, the employer must use an effective means of preventing the machine from automatically restarting -- but no particular means is specified in the standard. While an employer may use any effective means of meeting this requirement, we are not aware of any device other than a magnetic type switch that would meet this requirement.

Assuming the blade guard is in place, does having a warning sticker on the saw and training employees to recognize the hazard suffice to meet the intent of the standards [§1926.304]?

No. Since the restoration of power can be as unexpected as the loss of power, a warning sticker and training would not eliminate the hazard.

Are there differences in the 1961 and 1992 ANSI [Woodworking Machinery] standards that we should be concerned with? If we are required to follow the 1961 standards, how do you suggest we obtain a copy?

The 1961 ANSI standard is a slightly modified version of the 1954 ANSI 01.1, Woodworking Machinery. To our knowledge, copies of the 1961 version are no longer available from ANSI. We have enclosed a 1954 ANSI standard with the 1961 changes indicated by strike outs and insertions.

There are many differences in the 1961 version and the 1992 revision. An employer may follow the provisions in the 1992 version that are more protective than the 1961 standard. Please let us know if you want us to comment on particular provisions of the 1992 standard in this regard.

If you require further assistance, please do not hesitate to contact us again by writing to: Directorate of Construction- Office of Construction Standards and Compliance Assistance, Room N3621, 200 Constitution Avenue, N.W., Washington, D.C. 20210.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction