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• Standard Number: 1910.215(d)(3)

January 3, 1980

MEMORANDUM FOR:   AREA DIRECTORS
                  DISTRICT SUPERVISORS

FROM:             DAVID H. RHONE
                  Regional Administrator

SUBJECT:          Interpretation of 29 CFR 1910.215(d)(3)

In response to an inquiry from Donald L. Morgan, Esquire, of Cleary, Gottlieb, Steen & Hamilton, the law firm representing American Cyanamid Co., the National Office of Compliance Programming has interpreted the subject standard on abrasive wheels in the attached letter dated December 26, 1979.

It is important that all members of your safety staff realize the significance of the attached interpretation which specifies the "contact surface" of the abrasive wheel as the mounting surface and not the grinding face as previously interpreted by some CSHOs.

Questions on this memorandum may be directed to Bill Thomas in the Technical Support Group of this office.

Attachment





Donald L. Morgan, Esquire
Cleary, Gottlieb, Steen & Hamilton
1250 Connecticut Avenue, N.W.
Washington, D.C. 20036

Dear Mr. Morgan:

This will confirm a telephone conversation with a member of my staff, Mr. Joe Bode, regarding your request for an interpretation of 29 CFR 1910.215(d)(3), pertaining to a citation alleging a violation issued to the American Cyanamid Company at Willow Island, West Virginia on March 21, 1979. Please accept our apology for the delay in response.

The grinding face of an abrasive grinding wheel is not a contact surface within the meaning of the regulation.

The standard 29 CFR 1910.215 addresses abrasive wheel machinery, often referred to as grinders. The OSHA standard was adopted from portions of the American National Standards Institute consensus standard, ANSI B7.1-1970. Pages 2 and 52 of that document, copy enclosed, verify that the standard, as it was applied in this instance, was misconstrued. The surface of hazardous concern, as presented in your letter, was the grinding surface or face per ANSI definition. The contact surface, as clarified by ANSI under explanatory information, specifically concerns the mounting surfaces on the wheel.

I hope this reply is responsive to your needs. Mr. Crawford, Solicitor for OSHA, will be in contact with you. If I may of further assistance, please feel free to call or write.

Sincerely,





Donald A. Shay, Director
Office of Compliance Programming


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