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.

November 14, 2003

John Kurtz
Executive Vice President
International Staple, Nail and Tool Association
512 West Burlington Avenue, Suite 203
La Grange, Illinois 60525-2245

Re: Use of quick-disconnect on pneumatic power tools; §1926.302(b)(1)

Dear Mr. Kurtz:

This is in response to your letter dated May 22, 2003, regarding the federal construction standard for power-operated hand tools. Your concern is whether a pneumatic tool connected to a hose by a quick-disconnect device satisfies the requirements of §1926.302(b)(1). Based on your August 19, 2003, e-mail you indicated that some pneumatic tools have a quick-disconnect composed of a male fitting (connector) and female fitting (coupling). The coupling has a sleeve which must be pulled away from the end of the hose to separate the two fittings.1

Question (1): Does the use of a "quick disconnect" with a "pull-down sleeve" satisfy the requirements in §1926.302(b)(1)?

Answer:
Section 1926.302(b)(1) states:

Pneumatic power tools shall be secured to the hose or whip by some positive means to prevent the tool from becoming accidentally disconnected.

 

 

The purpose of this requirement is stated in the plain language of the provision itself - "to prevent the tool from becoming accidentally disconnected." This requirement addresses the hazards associated with having a pressurized air hose whipping around if it were to become accidentally disconnected from the pneumatic tool.

You described a quick-disconnect with a "pull-down sleeve." In order to separate the tool from the hose, the sleeve must be grasped and pulled down against the resistance of a spring. This type of device is a "positive means" of preventing the tool and hose from accidentally separating since it is designed to prevent the hose and tool from becoming accidentally disconnected. Therefore, it meets the requirements in §1926.302(b)(1).

If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction

 

 

1 You also stated that this coupling "typically has an integral check valve" that prevents pressurized air from escaping from the hose when the tool is disconnected. While that is an additional safety feature, we have analyzed your question with respect a quick-disconnect without an integral check-valve. [back to text]